Managing Safely RRC BUSINESS TRAINING 27-37 St George’s Road, London SW19 4DS Tel +44 (0)20 8944 3100 • Fax +44 (0)20 8944 7099 support@rrc.co.uk • www.rrc.co.uk The Course Writer Technical Writer Dr J Phelpstead BSc, PhD, MIOSH, RSP Jim originally trained as a crop plant geneticist before changing careers to work in the food industry. He has worked as health and safety manager with blue chip food manufacturing companies at various locations in the UK. He is now an independent consultant and trainer. RRC Module No. 934A.2.1 Copyright © RRC Business Training All rights reserved No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form, or by any means, electronic, electrostatic, mechanical, photocopied or otherwise, without the express permission in writing from RRC Business Training. Managing Safely C O N T E N T S Section One: Managing Safely and Safety Management Systems Introduction Working Safely Safety Management Principles Integrated Management Systems Safety Management Elements Summary Section Two: Reactive Monitoring Definitions Investigation of Accidents Statutory Requirements for Reporting Accidents Recording of Accident Data Analysing Incident Data Incident Investigation Summary Section Three: Risk Assessment and Risk Control General Principles of Risk Assessment The Meaning of Hazard The Meaning of Risk Risk Control Systems Summary Section Four: Health and Safety Legislation Introduction Criminal and Civil Law Information Resources Health and Safety Law Advisory and Enforcement Bodies Health and Safety Offences Health and Safety Responsibilities Summary Appendix Section Five: Management of Common Hazards Maintaining Safe Working Conditions Workplace Hazards Fire Principles Fire Risk Assessments Evacuation Procedures Electricity Hazards Manual Handling Mechanical Handling Hazardous Chemicals Display Screen Equipment Noise at Work Summary Section Six: Active Monitoring General Principles of Active Monitoring The Active Monitoring Inspection Process Auditing Performance The Audit Process Carrying Out an Audit Summary IOSH Certificate | Managing Safely C O N T E N T S Section Title 1 Page Managing Safely and Safety Management Systems 1-1 Introduction 1-2 Working Safely 1-3 Safety Management Principles 1-7 Integrated Management Systems 1-10 Safety Management Elements 1-14 Summary 1-25 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 1 | Managing Safely and Safety Management Systems Learning Objectives When you have completed this section you should be able to: ! Explain ‘working safely’ ! Outline the legal, humanitarian and financial reasons for implementing workplace safety ! Explain the component parts of a recognised safety management model such as HSG65 or BS 8800 ! Appreciate the role of risk assessment ! Compare safety management systems with other management systems ! Describe how to integrate systems successfully if appropriate. Unit 1: © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-1 IOSH Managing Safely INTRODUCTION Health and safety at work is achieved by preventing accidents and ill-health. Prevention should be given the same priority as other matters, such as progress and profit. Here we will outline how to manage safely in the workplace and implement safety management systems. 1-2 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely WORKING SAFELY Defining Working Safely ‘Working safely’ is taking on more and more importance these days. Trade unions and works committees take an active interest in promoting healthier and safer working conditions of their members as part of their policy in improving the quality of working life. Most people have heard of the Health and Safety at Work etc Act 1974 even if they have never read it or are not familiar with its contents. All employers and managers are aware that the Health and Safety Executive (HSE) exists, even if they have never come across any of its inspectors. But what does ‘working safely’ mean? You might answer one of the following: • It’s about preventing accidents • It’s ensuring the workplace is safe • It’s common sense • It’s about making people follow rules Each answer is correct but only to a degree. Before we can talk sensibly about ‘managing safely’, we must understand what the concept means: An accepted definition is: Working safely is carrying out your job in such a way that you do not put yourself or others at risk of injury, or threaten their health or well-being. It is an objective to be achieved, not a natural state of affairs. Reasons for Working Safely Health and safety at work is achieved by preventing accidents and ill-health. Prevention should be given the same priority as other matters, such as quality, progress and profit. There are four main reasons for implementing health and safety in the workplace: • Humanitarian Past experience has shown that most accidental deaths, injuries and illness could have been prevented. Most people would be concerned if their action or inaction was shown to result in someone else's suffering. Attitudes in society focus increasingly on health, safety and environmental issues. The media regularly expose instances of risk to people's health and safety. Employee morale, customer relationships and public relations can all be adversely affected by a company's poor accident or ill-health record. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-3 IOSH Managing Safely • Legal Health and safety legislation covers all aspects of work. It places health, safety and environmental duties on employers and employees. There is also a legal system for compensating people who have suffered injury or ill-health. • Economic Difficulty in identifying the cost benefits of safety improvements is one of the fundamental problems when planning for health and safety. Such improvements are seen as bottom-line expenditure, which can only be justified where there is a clear legal obligation. There are a number of reasons why savings made by such improvements are less easily identified: • − The costs of injuries/damages are rarely estimated − Many accidental losses are not recognised as such, the losses are simply absorbed into various budgets − There is rarely adequate information from which to calculate a reduction in accidental loss. Insurance Claims under employers' liability insurance have outstripped premium increases in recent years, for a number of reasons: − Increased public awareness and concern about health − People are more ready to claim − Compensation claims and legal costs are continuing to rise − Insurers are concerned by the cost of health hazards (particularly issues such as workrelated upper limb disorder and passive smoking). Employers' liability insurance is a legal requirement but insurance premiums can rise dramatically for employers who cannot show evidence that risks are being managed. Some companies may well become uninsurable. Many of the factors listed above are not covered by insurance. One study showed that uninsured losses were between 8 and 36 times greater than insured losses. Look at the following figure, which shows a summary based on a study of five industries studied (from The Cost of Accidents at Work, HSG96). 1-4 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely Insured costs Include injury, ill-health, damage to property Uninsured Costs Include legal costs, emergency supplies and equipment; overtime; recruitment and training; extra administration; fines The Cost of Accidents at Work Activity 1 In the following scenarios, identify direct (insured) costs and indirect (uninsured) costs. (a) A cake decoration manufacturer is fined £6500 plus £1312 costs after an operator’s finger is amputated after it is trapped in between the rollers in a rotary moulding machine, where a safety hopper device was missing. The operator was unable to work for months. (b) An engineer falls 150 ft down a skyscraper lift shaft. He suffers severe head injuries and the lift is rendered inoperable for a week during repairs. (c) A building contractor is fined £25,000 plus costs when a mobile crane is inappropriately used to lift large concrete slabs from the back of a lorry to a mezzanine floor. One of the slabs falls two metres onto a banksman who is killed instantly. (d) A company is fined £350,000 with £14,500 costs when a 19 year-old untrained operative is killed while driving a fork-lift truck which overturned. There was also severe damage to warehouse racking and to crates. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-5 IOSH Managing Safely Accidents give rise to: • Direct costs - such as medical care (as in (a) and (b) in the Activity box), repairs to damaged equipment and buildings (as in (b) and (d)); and • Indirect costs - such as legal costs and additional clerical work engendered by legal proceedings ((a) (b) and (d)); time spent on extra repairs ((b) and (d)); lost time due to attendance to court proceedings, hospital visits and loss of victim’s production (as in (a)); recruitment and training (in (d) a new warehouseman will have to be recruited and trained in the use of fork lift truck driving); lost orders and goodwill (again in (d) goods will have been damaged and will no doubt have to be replaced before completing orders to customers). 1-6 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely SAFETY MANAGEMENT PRINCIPLES Most organisations have a management system in place for one or more aspects of general management. Some companies prefer to install a quality management system, e.g. ISO 9000. Another important type of management system is the Environmental Management System, ISO 14001. Both can be audited by an external agency and accreditation received by the company. A new standard for health and safety (ISO 18000) has recently been introduced based on the ISO 9000 and ISO 14000 model of continual improvement. This is not the only Safety Management System available. The Health and Safety Executive have published their own model in the document “Successful Health and Safety Management”, identified by the code HSG65. There is also a British Standard, BS8800: Guide to Occupational Health and Safety Management Systems. Loss Management Model It is worth introducing the loss management model at this stage as this will also form a significant element of the programme. This model, shown in the following diagram, will be considered in greater detail when we look at Monitoring and Risk Assessment. Loss Management Model © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-7 IOSH Managing Safely The loss management model can be considered as three main branches or management processes: • The first (left-hand side) branch is Reactive Monitoring. This is the process of reporting, recording and analysing near miss, injury and ill-health events in the workplace. Individual accidents or incidents may be investigated to determine their cause and allow corrective action to be taken. Alternatively these incidents may be analysed using statistics to identify patterns or trends in the workplace. This, in turn, may allow corrective actions to be taken to address underlying causes. Essentially reactive monitoring can be considered as learning from past experience. • The second (middle) branch or process of the loss management model is Risk Assessment. This involves identifying things that could go wrong and taking corrective action before they actually do go wrong. Risk assessment is the central core of all health and safety management. • The third (right-hand side) branch of the model is Active (or Proactive) Monitoring. This is the process of checking that the controls put in place as a result of risk assessments or accident investigations are in fact kept in place. Carrying out a workplace inspection is one form of active monitoring. Confirming that machine operator training records are up-to-date is another form of active monitoring. All of these processes allow workplace precautions and risk control systems to be identified. The workplace precautions are the controls which have to be in place to prevent a particular hazard from causing harm (for example, a fixed guard over a dangerous moving part of machinery). The risk control system is the management system introduced to ensure that the workplace precaution remains effective (for example, the machine operator must be trained or they may not recognise the importance of the fixed guard). Successful Health and Safety Management Similar to the above management approaches, there is a specific management model for health and safety defined by the Health and Safety Executive. This is commonly referred to as HSG65 (so called because of the reference number given to an HSE document called Successful Health and Safety Management). 1-8 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely HSG65 consists of six well-defined steps, as shown in the following figure. A company should put all these in place to achieve a good safety management system. We will consider each of the six steps in detail in this and the following study sessions. Organising Auditing Planning & Implementing Measuring Performance Reviewing Performance Feedback loop to improve performance Policy The HSG65 Model Although HSG65 is not the only safety management model it does provide a structured management system that can be readily introduced to all organisations and as such has been adopted as a general structure to this course. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-9 IOSH Managing Safely INTEGRATED MANAGEMENT SYSTEMS A well-managed organisation, in terms of health and safety, fits in perfectly with the concept of a quality company. We will now look at the similarities between total quality management and health and safety management. Quality Management • Quality Control A reactive management system in which the output of a process is controlled simply by being accepted or rejected. The process is adapted to reduce rejects. • Quality Assurance Goes one step further. Sets specifications for raw material input; equipment; methods and output. The output specification is assured if the input and process specification are met. • Total Quality Management (TQM) Goes beyond quality assurance, adding the crucial factor of good attitude and behaviour of everyone involved in the process. It includes willingness to consider everyone within the process as an internal customer. All customers, internal and external, are listened to and their views acted upon to produce total quality. Thus quality is a primary consideration of everyone at all times. Health and Safety Management We can consider the three levels of quality in relation to health and safety management, taking the health and well-being of employees (and others) as the aim. • Health and Safety Control Employees input into the process. The work safety process is vaguely specified, mostly in terms of rules, verbal instructions and historical codes of practice. Output is controlled, i.e. if there are no accidents, the situation is deemed acceptable. If accidents do occur, then the situation is deemed a reject condition. • Health and Safety Assurance Employees are expected to meet an input specification , typically in terms of qualifications and abilities. The work safety process is rigorously defined in terms of the application of directives that form part of the company's health and safety policy. Safety management is clearly defined and responsibilities are clearly allocated. This requires detailed specifications of: 1-10 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely PLANT (Tools, equipment, protective devices) PLACE (Environment, access, egress, storage) COMPETENCE (Training, qualifications, supervision, provision of information) SYSTEM (The safe conjunction of employee, workplace, equipment and work method) Output from the work safety process must also meet a specification. Typically, dependent on the organisation, fitness and health are monitored and medical examinations included where risks are high. By following such a process, the health and safety of employees is assured. • Total Health and Safety Management As with TQM systems, total health and safety management involves people and their attitudes. The input specification for employees includes such parameters as motivation, awareness, training, information and knowledge of the rules and regulations. The work safety process now involves not just a set of procedures but people treating each other as safety customers. There is good communication and supervision which is based on the requirements of plant, place, competence and system. The output specification for the health and safety of employees is thus assured and safety performance should be right first time, every time. Environmental Management Management systems are a key element in the continued success and growth of a company. Integrated assessment, combining the disciplines of quality, environment and health and safety in a single audit, is on the increase. You can develop your own environmental management system (EMS) as an internal management tool. Alternatively, there are recognised national and international standards which provide accreditation and external recognition of the standards achieved. ISO 14001 (Environmental Management Systems - Specification with Guidance for Use) and EMAS, (the EU's Eco-Management and Audit Scheme), are the two most important guidelines to affect environmental management systems. Launched in September 1996, ISO 14001 was introduced as the quality standard, detailing how environmental systems should be implemented. It ensures organisations wishing to achieve the standard understand how their activities impact on the environment and how they might improve © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-11 IOSH Managing Safely their performance in this respect. In order to achieve the standard, organisations need to meet five requirements: Establish a company environmental policy To fit in with the activities of the organisation and include plans to improve control of environmental pollution. Plan To meet objectives and targets to address company environmental impacts. Implement and operate system To allocate roles and responsibilities to skilled personnel and provide necessary technical and financial resources. Monitor system To take corrective action where necessary. Management review To assess the effectiveness of the system. ISO 14001 Model 1-12 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely Activity 2 (a) What five elements are common to all management systems as embodied by ISO 14001 and HSG65? (1) (2) (3) (4) (5) (b) How might you differentiate between health and safety control and health and safety assurance? The following characteristics are shared in common: (a) Preparing a written policy; organising roles and responsibilities; planning and implementing safety procedures; measuring performance; reviewing performance targets and operation systems. We can distinguish between control and assurance as follows: (b) Control is a reactive process whereby systems are adjusted to limit damage or rejects; assurance is a proactive process whereby methods are clearly specified to ensure maximum standards are met. In terms of health and safety, systems are controlled in the sense that if there are no accidents, then this is deemed satisfactory. Health and safety assurance on the other hand, goes further by setting out clear roles and duties to ensure that no or few accidents will happen. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-13 IOSH Managing Safely SAFETY MANAGEMENT ELEMENTS To be successful, management must acknowledge that health and safety plays an important role in all aspects of the organisation. It contributes to business performance and meets the organisation’s responsibilities to people and the environment in a way which fulfils both the spirit and the letter of the law. This session looks at the policy and statement of intent that managers should prepare with respect to health and safety in the workplace. Health and Safety Policy Policies should be cost effective. They should aim to preserve and develop physical and human resources, and reduce financial losses and liabilities. It is important to differentiate between a policy as defined by HSG65 and the statement of intent that should be included within a company's Safety Policy (Health and Safety Policy) as required under the Health and Safety at Work etc. Act 1974 (HSWA). Indeed, HSWA requires that a policy include many of the key elements identified within HSG65, such as the organisation and monitoring of safety arrangements as well as the responsibilities of staff. The Policy element of HSG65 should reflect the Statement of Intent as required by HSWA, providing clear direction to all employees as to the aims and objectives of the organisation. Written by the senior managers, the general statement of intent should express the long-term, strategic safety and health aims of the organisation and declare the commitment of management to pursue policies which will ensure the continued health and safety of all the workforce. 1-14 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely The general policy statement should cover at least five clear elements: Management commitment To show senior management commitment to health and safety, a senior manager should sign the document and accept the ultimate responsibility for the health, safety and welfare of all the employees. Management compliance The organisation must comply with all relevant statutory requirements and expects employees to do the same. Penalty for noncompliance The organisation should see failure to comply with the health and safety regulations as an important breach of the contract of employment and should act accordingly. Importance of health and safety The organisation should consider health and safety issues to be as important as commercial considerations. Expectations That management expects the co-operation of the employees to carry out their duties and to communicate freely to promote health and safety. General Policy Statement © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-15 IOSH Managing Safely Activity 3 Which of the following would you not expect to see in a Health and Safety Policy? (Tick the correct alternatives) (a) Fire safety arrangements (b) Emergency procedures (c) Dates of when equipment and materials were last inspected (d) Methods of reporting accidents and diseases (e) Arrangements for consultation with workforce (f) Details of training requirements and provision (g) Provision and use of protective clothing and equipment (h) Facilities for use and storage of highly flammable liquids and explosive substances (i) Environmental monitoring policy and arrangements The Health and Safety policy is a written statement specifying procedures, arrangements and responsibilities for health in safety in the workplace (all but (c) in the Activity box would apply). Organising for Safety Having determined your health and safety objectives, you need to set up procedures and allocate responsibilities to bring about progressive improvements in health and safety performance. Organisations must define the responsibilities and relationships which promote a positive health and safety culture. Organising for health and safety falls into four main categories called the four C's: • Control through the delegation of responsibilities • Co-operation between individuals and groups • Effective communications at all levels • The promotion of competence will aid in achieving your objectives while developing a culture that acknowledges the benefits of health and safety management. It is only through the visible and active leadership of managers that such a culture can be developed and maintained. 1-16 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely Control by Management To ensure that all employees understand their role in contributing to a safe working environment, management must set out clearly the responsibilities of each individual within the organisation. In the Statement of Intent, one senior manager (usually the employer) accepts all responsibility for the health and safety of employees. However, one manager cannot be in all places at once. Consequently the senior manager must delegate specific responsibilities through the management hierarchy to a named manager and ensure that safety is maintained. These duties are the core of the tactical objectives of middle managers charged with turning the strategic aims of the general policy into practice. Sets policies Senior management/ Board of Directors Implement policies Middle managers Carry out and monitor safe systems of work Supervisors/ Departmental managers Management Control Departmental managers are responsible for all aspects of health and safety within their area of control and in particular they are responsible for ensuring: © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-17 IOSH Managing Safely The implementation of the company’s health and safety policy. By preparing and implementing a departmental programme and by setting targets. Communication and consultation with employees on health and safety issues. By providing information, preparing clear job descriptions with job safety analyses and by meeting with employee representatives. Consideration of safe systems of work and environmental issues. By planning operations, providing PPE where necessary, maintaining plant and equipment, carrying out inspections, maintaining records and disposing of waste. Departmental Management Responsibilities Consultation and Co-operation Good safety performance depends on everyone in the organisation co-operating on all safety aspects and taking 'ownership' of safety policies. Several points are important in order to achieve this: Legal Requirement • It is a legal requirement to consult and co-operate with employees. Where trade unions are recognised, consultation must take place via safety representatives appointed under the Safety Representatives and Safety Committees Regulations 1977. When requested, employers must set up a safety committee to discuss regularly with all employee representatives issues relating to the health, safety and welfare of their members. • All other employees not represented through trade unions must be consulted in accordance with the Health and Safety (Consultation with Employees) Regulations 1996. • All representatives are entitled to reasonable time off from their work duties to carry out their health and safety duties. This time must be paid at their normal work rate. Adequate facilities must be provided in the organisation for such personnel to carry out their duties as safety representatives. Encouraging Consultation Many organisations go a step further than their legal requirement and actively support and encourage consultation. Well-trained safety representatives should be encouraged to participate in 1-18 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely the development of health and safety policies, measuring performance, investigating accidents and other incidents and generally helping to improve safety performance. Recent research shows that workplaces with safety representatives have half the accident rate of workplaces with no safety representative. Encouraging Employee Participation Everyone in the organisation should be encouraged to participate in safety matters, not just the safety representatives. Employees at all levels can become involved, either individually or in groups, to help: • Set safety standards and targets • Devise safe systems of work • Participate in risk assessments and safety inspections. Supervisors, team leaders and managers should also be encouraged to help set targets and standards for their own departments or functions. Forming ad hoc problem-solving teams to help solve departmental safety problems can greatly increase employee awareness of safety and can help considerably to gain the much-needed 'ownership' aspect of health and safety. Communications Communication is often seen as one of the most challenging aspects of improving an organisation. Barriers to communication must be overcome and effective routes of communication must be established. Communications will fail if there is a difference in attitude or experience between the communicating parties or if there are outside influences during the communication process such as: © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-19 IOSH Managing Safely Poor language skills A message may be misunderstood if we use language that not all can fully understand. People’s understanding will depend on their culture, background or experiences. Communication skills are the abilities to send and receive messages clearly and effectively, with no possibility of misunderstanding. This means expressing ideas in words that all can understand and are suited to the intended purpose of the communication, and using signs, symbols and body language in an appropriate manner. Poor listening skills The ability to listen is an essential skill for all of us. Unless we have it we are unable to understand what is going on around us, with potentially disastrous results. Take time to really listen to all of what someone is trying to tell you, not just to elements that you want to hear. Attitudes We all gain certain attitudes towards life through our education, environment and general experiences. If they are extreme, they are called prejudices. Whatever their form, they can distort our awareness of messages in communications and thus hamper the communication process. To communicate effectively, we must try to be aware our attitudes and those of the intended recipient, otherwise a further barrier may emerge. Incorrect or incomplete information Although communication may be effective, the message or information may be incorrect. This will undermine the recipient’s trust in the sender, and may create barriers in attitude which can hinder further exchanges. Outside influences (noise) Noise is the name given to the elements of the setting in which the communication takes place and which interfere with the accurate transfer of information. In literal terms, it can be physical noise, such as heavy traffic, telephones ringing or people talking to you while you are reading a letter. It can also refer to other kinds of interference, such as a poor telephone connection or illegible handwriting. Barriers to Communication Many formal and informal routes of communication evolve within an organisation. Because it is not always possible to guarantee the effectiveness of the informal routes, a number of more formal routes must be established to ensure safety issues are progressed. It is important not to underestimate the benefits that can be achieved through the informal routes and as such they should be encouraged to complement the more formal approach. The more formal means of communication are likely to include: • Board meetings with a set health and safety agenda item • Safety committee meetings 1-20 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely • Health and Safety Policy • Formal reports • Training sessions • Written company procedures. Competence It is important that staff at all levels are competent in the tasks they are expected to perform if the organisation is to achieve high standards of health and safety. At management level this means developing strategies for: • Appointing competent staff where possible • Identifying competency and training needs in existing staff • Providing training where appropriate • Monitoring staff to ensure they continue to perform to expected standards Training can be effective in achieving health and safety awareness and competence. At times it is best to recruit the skills you require from outside. A well-defined job profile will ensure that recruits to a job have the necessary physical and mental capabilities to carry out the required tasks. However, the competence of existing staff cannot be overlooked and calls for: • Systems to identify health and safety training needs in relation to all personnel • The need for refresher training to ensure competence is maintained • Systems and resources to ensure the necessary provision of information, instruction and training • Good health promotion and surveillance schemes. Training For Managers Most managers see training as desirable since: • It increases productivity and quality • It reduces learning time on the job • It raises standards, including health and safety. Training For Employees From the point of view of employees, we can see additional reasons for training: • To enable new recruits to become competent and confident workers. The quick, correct and safe method of doing the task is learnt from the beginning and, as there is less risk of passing on bad and unsafe practices, machinery and equipment are used more effectively. • To achieve objectives with the least waste of time and resources as the best use is made of an employee's time within the company during the training period. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-21 IOSH Managing Safely • To facilitate their integration into the social working group. Recruitment of school leavers is improved; transition from school or previous company to the new environment is made less unsettling; and the element of personal challenge in a carefully-graded training course induces employees to try to match their talents to the demands of the job. • To assist workers who have to change their jobs within the company to regain their economic and social status with the least delay. When properly trained, employees tend to stay longer with the employer and, as they are inclined to identify themselves more fully with the company's interests, labour relations and labour turnover figures improve. Further training in stages builds up versatility, ability to accept an increasing degree of responsibility, and capacity to progress beyond the basic level. Safety training is of vital importance both to the company and employees, particularly new recruits. A newcomer could be run down by a fork-lift truck on the first day, or a fire could break out soon after his arrival. Safety and fire training should therefore begin on the first morning with the immediate dangers of the working environment and procedures to be followed in case of fire or accident. Later sessions should progress to the joint responsibilities of management and employees for safe working practices and give more detailed attention to the causes and prevention of, say, fire. Special attention should be given to the safety training needs of young people. Young persons under the age of 18 are particularly vulnerable to accidents and should be taught to act safely and obey safety rules from the very first day they join the company. All dangerous machinery must be effectively guarded but, because of the vulnerability of young persons, additional obligations exist in the cases of certain particularly hazardous machinery which has been specified by statutory regulations to be dangerous. Young persons must be under the adequate supervision of someone experienced who has a thorough knowledge of the machine. They must be fully instructed as to the dangers of the machine and precautions to be taken. Training Cycle Often training needs, or changes in behaviour, stem directly from the way in which an employee carries out a certain task. Job analysis and job safety analysis may indicate areas of work where performance could be improved through additional training. Performance appraisal interviews are another means through which training needs can be identified. In many cases the initiative will come from the employee and training will be requested to improve performance, reward and job satisfaction. Training should follow a systematic process or cycle. A typical training cycle should have the following steps: 1. Identify training needs The first step is to decide if training is necessary. Training should never be a substitute for other risk control measures and it is always better to eliminate a hazard completely, if possible at reasonable cost. However, if it is not possible and some other risk control measure is required, training should be given to ensure that the control measure is clearly understood and applied. 1-22 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely Look carefully at health and safety elements of jobs and tasks to try to identify training needs. Other methods you can use include: 2. − Consultation with individual employees − Gathering data on accidents and incidents − Direct observation of how jobs and tasks are carried out − Questioning employees about their knowledge − The risk assessment process − Data gathered from any other hazard-reporting system Identify training objectives Objectives and priorities should be set according to the criteria and data gathered in step (1). 3. Deliver training Training should be delivered in the most cost-effective way appropriate to the needs of the individual, the task and the organisation. Training may be carried out internally or externally to the organisation. 4. Evaluate and feedback All training, regardless of its style and who carries it out, should be evaluated for its effectiveness. This essential part of the training cycle is necessary to identify other training methods. Identify Training Needs Evaluate Training Effectiveness Prepare Plans to Meet Training Needs Implement Training The Training Cycle Careful analysis of the needs on which training should be based is the foundation of effective training. If training provisions are not based on an analysis of needs, or the analysis is inaccurate, then the chances of training being effective are substantially reduced. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-23 IOSH Managing Safely Activity 4 In your own organisation, what kind of training would you think necessary for: (a) New recruits (b) Managers (c) Technical personnel New recruits will require basic induction training in health and safety matters, company rules and practices, and more specific job training. Managers will have to keep themselves up-to-date on new legislation and work practices as well as in managerial functions. Technical personnel would generally require an update of their technical skills, particularly when new equipment or regulations are introduced. 1-24 Section 1 | Managing Safely and Safety Management Systems © RRC Business Training IOSH Managing Safely SUMMARY In this section we saw that most organisations have a management system in place for one or more aspects of general management. There are several management models for health and safety. We considered one of them, HSG65, which outlines six basic steps, all of which must be put in place by a company to achieve good safety management: • Preparing a written policy which sets targets and objectives for dealing with health and safety issues • Organising the roles and responsibilities of all employees to ensure they know what their part is in the overall safety management system • Planning and implementing health and safety procedures • Measuring performance and taking remedial action • Reviewing the whole safety management system to ensure it is operating effectively • Auditing the above steps. The primary role of a manager is to ensure safe workplace conditions and the observance of safe working practices, in order to limit the risk of accidents and ill-health. Managers must assess risks, investigate accidents and make recommendations for corrective action and protective controls. Optional Further Reading You may like to obtain a copy of HSG65, available from HMSO, St Clement's House, 2-16 Colegate, Norwich NR3 1BQ. © RRC Business Training Section 1 | Managing Safely and Safety Management Systems 1-25 IOSH Certificate | Managing Safely C O N T E N T S Section Title 2 Page Reactive Monitoring 2-1 Definitions 2-2 Investigation of Accidents 2-4 Statutory Requirements for Reporting Accidents 2-6 Recording Accident Data 2-9 Analysing Incident Data 2-14 Incident Investigation 2-18 Summary 2-32 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 2 | Reactive Monitoring Learning Objectives When you have completed this section you should be able to: ! Differentiate between accidents, incidents and dangerous occurrences ! Identify the data and techniques required to produce an adequate record of an incident ! Demonstrate the procedure for an accident investigation, recognising the human factors involved in accidents ! Describe statutory requirements for reporting and procedures for checking non-reporting ! Describe methods of basic trend and epidemiological analysis for reactive monitoring techniques. Unit 2: © RRC Business Training Section 2 | Reactive Monitoring 2-1 IOSH Managing Safely DEFINITIONS There are two approaches to measuring health and safety performance: • Active monitoring, which involves regular reviews of compliance with regulations and standards and looks at systems and conditions BEFORE accidents happen • Reactive monitoring, essentially an investigation of accidents, cases of illness, property damage and near-misses to identify why performance was substandard. Accidents Health and safety management is about preventing accidents and ill-health. Consider the following situations: • A worker puts his hand into a machine from which the guard has been removed and is injured • A piece of material is ejected from a machine and smashes a window • A worker trips and falls while running to the car park and sprains his ankle • The wrong material is fed into a process, and causes the plant to break down. All of these examples are accidents, although they do not all result in injury. Some will result in damage. What is important is that all accidents: • Are undesired • Are unplanned • Result in loss, which can be death, injury, illness, damage, production delays or financial loss. Injuries Some injuries have to be reported to the enforcing authorities under specific legislation. Such injuries are termed “reportable” injuries and include: • Fractures other than to fingers, thumbs or toes • Dislocation of the shoulder, hip, knee or spine • Loss of sight • Chemical or hot metal burns or penetrating injuries to eyes • Electric shock or electrical burns leading to unconsciousness • Asphyxia or exposure to harmful substances or biological agents. Ill-health Work-related ill-health covers any condition caused or worsened by an industrial situation. It is not always possible to know to what extent a condition is due to activities outside or in the workplace 2-2 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely (e.g. lung cancer might be caused by smoking or it might be caused by exposure to asbestos. It is not always possible to identify which was the actual cause of the cancer during a post mortem). Acute illnesses due to toxins, infected material, absorption of substances by inhalation or through the skin, requiring medical treatment are reportable. Chronic effects arise where harm develops slowly over a period of time (e.g. asbestosis). Acute effects, although less common, arise quickly, usually due to one large over-exposure to a substance, e.g. gassing accidents. Damage to Property Damage-only incidents are those where there is no resulting injury or ill-health to people, but where property, plant or equipment may be damaged. Near-misses or Incidents While some occurrences can have the same causes, they do not necessarily end in loss: • A worker realises that the guard is missing on a machine and pulls out his hand, with no more than oil smeared on his fingers • A piece of material is ejected from the machine and lands on the floor of the workshop some distance away • The worker running to the car park stumbles but regains his balance and carries on • The wrong material is fed into a process but this is noticed before it can affect the plant. These types of event are often called near-misses or near-hits and most safety practitioners would call them incidents. Dangerous Occurrences Some near-misses have to be reported to the enforcing authorities under specific legislation. Such events are termed “dangerous occurrences”. They represent the most serious types of near-miss because the potential for death or major injury is very significant indeed. © RRC Business Training Section 2 | Reactive Monitoring 2-3 IOSH Managing Safely INVESTIGATION OF ACCIDENTS The Accident Triangle It is important to report accidents, ill-health and near-misses in order to remove hazards, introduce safeguards and improve training and supervision. Reporting accidents is also important to help prove that a particular accident occurred at work. Accidents fall into two categories: • A near-miss is an incident which does not result in a injury or loss but could have done so • An accident is an unplanned occurrence which results in injury, death or damage to plant and equipment. Researchers (Heinrich and Bird & Loftus) have examined many accident statistics and have determined similar results which can be described in a triangular diagram: For every 1 SERIOUS INJURY There are 10 MINOR INJURIES 30 ACCIDENTS WHICH DAMAGE PROPERTY 600 NEAR-MISSES 000’s OF UNSAFE ACTS AND CONDITIONS The Accident Triangle The accident triangle is an important concept because one way to reduce property damage, minor injuries and serious injuries in the workplace is to focus on the base of the triangle, the ‘nearmisses’. Many organisations have successfully reduced their serious injury figures by encouraging the reporting, investigation and correction of near misses. This follows from the principle that if the base (or foundation) of the triangle is made smaller, then the other sectors of the triangle will become smaller too. This simply reflects the fact that a near-miss is, in effect, a warning shot across the bow. Unless the causes of the near-miss are addressed, then the event will happen again and 2-4 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely may cause an injury when it does. Many large-scale disasters could have been avoided if the warning signs of near-miss incidents had been heeded. What Should be Investigated? Since an incident could cause a fatality, a serious injury, a minor injury or a near-miss, all incidents should be investigated. As we have stressed, the purpose should be to find the cause, with the intention of preventing a recurrence, rather than to apportion blame. An injury usually involves some degree of blame falling on management, the supervisor, the victim and his workmates. This is often non-productive and does little to improve the situation or prevent recurrence. In fact, blaming people following accidents can have a detrimental effect on accident reporting and investigation. Workers may simply stop reporting accidents and incidents and withhold information from the investigation if they feel they may be blamed for events. Accident and Incident Reporting Before any accident can be investigated it must first be reported. Reporting is an important part of the management process because: • It is impossible to prevent a recurrence if you are unaware of the first occurrence • Specific regulations require employers to report certain types of event to the enforcing authorities. It is not possible to report if you are unaware of the incident occurring • Accident reports may help to substantiate or refute claims for compensation • Analysis of accident statistics may show significant trends or patterns which are not immediately obvious to the manager or safety officer. If reporting is poor such figures may be meaningless • Line managers have a legal responsibility for their staff. This automatically makes it in managers’ interests to know about accidents and incidents happening to their staff. Having stated that accident and incident reporting is important, it is worthwhile considering ways in which reporting can be encouraged and improved. Emphasising continuous improvement and the need to prevent recurrence are obvious things to do. Ensuring that staff understand the importance of reporting and the legal duty they hold might also be worthwhile. Having a very simple and user friendly system will encourage its use. No one wants to have to fill-in a 16-page form to report a cut finger! Ensuring that the accident book or report forms are in an easily accessible central location may also encourage their use. Training staff so they understand the reporting systems and procedures will also play a part. In the long term the most effective motivator will be management actions. Actions speak louder than words, so operating a “no-blame” culture, which addresses the root causes of accidents in the workplace and provides feedback to staff, will encourage continued good reporting in the long run. © RRC Business Training Section 2 | Reactive Monitoring 2-5 IOSH Managing Safely STATUTORY REQUIREMENTS FOR REPORTING ACCIDENTS Under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) employers and self-employed people must report certain types of accident, incident and illhealth in the workplace. You should notify the enforcing authority without delay if a member of the public or the workforce suffers a major injury or is killed. Reportable major injuries include: • Fractures other than to fingers, thumbs or toes • Dislocation of the shoulder, hip knee or spine • Loss of sight • Chemical or hot metal burn to eye or penetrating injury to the eye • Electric shock or electrical burn leading to unconsciousness or requiring resuscitation or hospitalisation • Asphyxia or exposure to harmful substances or biological agent • Acute illness requiring medical treatment due to toxins, infected material, absorption of a substance by inhalation, ingestion or through the skin. The Regulations also require the immediate reporting of dangerous occurrences. These are nearmisses with very significant potential for major injury or death and are listed in the Regulations. Over-three-day injuries also have to be reported to the authorities, which can be done by post or over the internet within 10 days of the event occurring. A phone call does not have to be made. Over-three-day injuries are those injuries arising from workplace accidents which render the injured person unable to perform their normal work duties for four consecutive days or more. Certain types of ill-health (for example, lead poisoning) have to be reported under the Regulations. Again there is a full list of all of the various types of ill-health which must be reported in the Regulations themselves. All reportable events must be reported on the standard form (usually the F2508 form) within 10 days of the event occurring. See the next page for a copy of the form. 2-6 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely Form F2508 Page 1 © RRC Business Training Section 2 | Reactive Monitoring 2-7 IOSH Managing Safely Form F2508 Page 2 2-8 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely RECORDING ACCIDENT DATA Accident investigation forms are used to provide management with an objective tool measuring and evaluating safety performance. This section looks at the format of the forms in detail and considers how they can be used to best effect. Completing Report Forms Report forms are usually printed or duplicated forms supplied in blocks or pads. They have a standard layout according to the type of accident. Using standard report forms enables essential information to be given in a concise manner. This facilitates any subsequent investigation. • Read the form carefully and decide just what it is you are being asked to record • Ensure the information you give is accurate to the best of your knowledge. If necessary, check any facts before committing them in writing • Include all relevant facts. Unfortunately many forms are poorly designed so, if there is insufficient space for your response, give it on a separate piece of paper and attach it to the main document • Sometimes the form will ask for your comments, conclusions or reasons, and every effort should be made to ensure they are properly presented in a logical fashion • Your statements should be written LEGIBLY. They will be worthless if they cannot be read. Form F2508 (see previous pages) has been produced by the Health and Safety Executive and should be used for reporting accidents involving more than minor injury and for serious, dangerous occurrences. If a person dies within one year as a result of a reported injury, the employer is required to report this as soon as it comes to his knowledge. Similar information should be kept for minor injuries. The safety practitioner should design a suitable form to ensure he or she gets the information required for investigations. Reporting of nearmisses requires some careful thought. It could involve a report by the supervisor or some sampling and interview technique. Report Format The form is completed as a record of the investigation, but since the requirements of different work environments vary, there is no such thing as a standard report form. Generally the report form should include the following information: • Name and personal details of the person who had the accident • Date, day and time of the accident • Where the accident happened, i.e. department and specific location • The job being done at the time © RRC Business Training Section 2 | Reactive Monitoring 2-9 IOSH Managing Safely • The actual occupation of the person involved • The nature of the injury or damage • Who had control of the cause of the injury or damage • What happened • What caused the accident, i.e. physical conditions and acts of persons • Immediate remedial action • Recommendations to prevent such an accident in future. Using Accident Information Accident records are useless if they are used only to compile numbers. They should be used as a tool to help control the accidents that are causing the injuries and damage. Detailed and thorough study of the records as part of the normal ongoing accident prevention programme should yield the following useful information: • The relative importance of the various injury and damage sources • The conditions, processes, machines and activities causing injuries and/or damage • The extent of repetition of each type of injury or accident in each operation • Accident repeaters, i.e. those workers who tend to be repeatedly injured or who are involved in more accidents than others • How to prevent similar accidents in the future. Recording Procedures The requirements for reporting accidents covered in the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) are summarised in the following graphic. 2-10 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely ACCIDENT ACCIDENT INVOLVING INJURY FATALITY OR SPECIFIED MAJOR INJURY OVER 3 DAY INJURY ACCIDENT BOOK ACCIDENT BOOK + + COMPANY ACCIDENT FORM COMPANY ACCIDENT FORM + + FORM F2508 FORM F2508 NOTIFY HSE IMMEDIATELY NOTIFY HSE WITHIN 10 DAYS NEAR MISS MINOR INJURY ACCIDENT BOOK DANGEROUS OCCURRENCE NEAR-MISS REPORT NON-REPORTABLE NEAR-MISS REPORT FORM F2508 NOTIFY HSE IMMEDIATELY SPECIFIED MAJOR INJURIES AND REPORTABLE DANGEROUS OCCURRENCES ARE LISTED IN RIDDOR GUIDE HSE 11 (Rev) Report Writing Techniques As a manager you may have to write full reports on health and safety matters. The following are the contents of a substantial report. Reports of a short or summary nature may omit many of the contents listed. It is largely a matter of personal and organisational choice, together with knowledge of the intended reader, which governs the structure and format of health and safety reports. © RRC Business Training Section 2 | Reactive Monitoring 2-11 IOSH Managing Safely Title Page The title should encapsulate the content of the report in a few words. The page should also indicate the date of origin of the report, the author(s) and the circulation list. Contents Page For long reports it is useful to include a list of contents. This will assist the reader to locate sections of interest rapidly. Introduction This should contain a brief overview of the remainder of the report. It should state why the report was written, the main conclusions and the recommendations. Method This section details the nuts and bolts leading to the conclusions which come later. It is frequently written in chronological order, like a log-book or diary, and is sometimes called the narrative section. In essence it ‘tells the story’ of the events leading to the report being written. Findings Here are the key factors extracted from the method section and on which the conclusions are based. For example, some key findings that may have emerged could be: • Injured person found unconscious near fallen stepladder • Stepladder situated beneath a lighting unit • Several smashed bulbs were found in the near vicinity • Bulb found to be missing from lighting unit. Conclusions Conclusions are drawn from the findings and are the manager’s considered opinion as to the facts of the case. From the above the conclusion may be drawn that: The injured person was engaged in the task of renewing defective light bulbs. He was changing a light bulb when, possibly because he was holding too many bulbs and was not grasping the ladder, he fell and struck his head and was rendered unconscious. 2-12 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely Recommendations These should follow naturally from the conclusions. For example, in the scenario above, personnel should be informed that the safe method of work for changing light bulbs involves keeping the hands free so that a firm grip can be kept on the stepladder. If this cannot be achieved easily then two people should be assigned to the task so that one person can steady the stepladder. Appendices These should contain copies of accident forms, sketch plans and also any photographs taken. Any other items of interest mentioned in the main body of the text should be included. Activity 1 (1) What is the purpose of in-house accident reports? Tick the appropriate alternatives. (2) (a) They give information on the number of accidents and near-misses in each department. (b) They give details of people who are most at risk. (c) They allow management to monitor processes and equipment which cause the most accidents. (d) They name the person in charge at the time. When would you use Form F2508? Tick the appropriate alternatives. (a) (b) (c) (d) (e) for minor injuries for serious dangerous occurrences for accidents involving fatalities for minor near-misses for major injuries The answers to the activity are: (1) All are useful except (d); (2) You should have ticked (b), (c) and (e). © RRC Business Training Section 2 | Reactive Monitoring 2-13 IOSH Managing Safely ANALYSING INCIDENT DATA Types and Uses of Accident Ratios Much of the accident data collected by the HSE is used to generate the statistics required by legislation. Other uses are to: • Classify industries according to risk • Classify workplaces • Classify occupations • Consider accident trends • Consider parts of the body injured - use of protective clothing • Use “cause of injury” to determine hazards in a workplace • Consider where the fault lies • Measure the effect of preventive/control measures. In making comparisons between various industries, or between work areas in the same factory, it is useful to consider the commonly used accident and disease ratios. Probability This is the chance that a given event will take place. It is a fairly simple concept when considering chance events such as throwing dice: P(A) = Probability of event A = m n Number of results giving A Total number of results For example, the probability of throwing a six is one in six, or one sixth. The probability of a lossmaking event, such as a personal injury or damage to a piece of machinery, can be determined from company statistics for the industry, country or the whole world. Company statistics will be more relevant but the small sample numbers make them statistically less valid than the larger numbers of world statistics. Sometimes it is only possible to make a subjective judgment as to whether the probability is negligible, low, moderate, high or definite. Incidence Rate The most frequently used accident statistic is the incidence rate. This can be calculated for any time period (month, year) and is: Number of reportable accidents × 1000 Average number of employees on site during the given time period 2-14 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely It gives a measure of the number of reportable accidents occurring over a given time per one thousand employees. The HSE often report national statistics using the incidence rate per 100,000 employees. Frequency Rate This can be calculated for any time period (month, year) and is: Number of lost - time accidents × 100,000 Number of man - hours worked It is a measure of the number of accidents per 100,000 hours worked. Severity Rate This is calculated as: Total number of days lost × 1,000 Total number of man - hours worked It is a measure of the average number of days lost per 1,000 hours worked. In measuring potential losses, both indirect and direct losses must be considered. Limitation of Accident and Ill-health Ratios HSWA makes the employer responsible for health as well as safety in the workplace, because death and lost working days are due more to illness rather than accidents. The RIDDOR Regulations give a list of specific diseases and conditions relating to occupational hazards. However, some workrelated hazards giving rise to poor health are not mentioned in this list because it is not always possible to know to what extent a condition is due to activities within or outside the workplace. Some factors that might affect health might be: • Smoking - cause of 90% of lung cancer • Passive smoking - workers who have to breathe air polluted by smokers • Poor diet • Excess eating • Alcohol • Lack of exercise • Too much or inappropriate exercise • Dangerous sports • Drug abuse. An ill-health condition caused by an activity other than work can be made worse by an industrial situation. Compensation is only paid for work-related conditions and it can be difficult to establish precisely where the problem lies. However, HSWA requires a safe workplace and a safe environment, even for employees who live very risky lives away from work. © RRC Business Training Section 2 | Reactive Monitoring 2-15 IOSH Managing Safely Epidemiological Analysis and Techniques Epidemiology involves observing the effects and studying the causes of ill-health and disease. Information can be gathered from national records, such as birth and death certificates and morbidity records, and local medical and trade union records and surveillance of high-risk workers. It is important to ensure that there is a definite relationship between a disease’s cause and effect, which can only be achieved if results and data are consistent, specific and biologically plausible. Types of Study There are two main types of epidemiological study: • Cross-sectional studies These involve a “snapshot” of the relevant workforce, examined over a short period of time. The advantage of this type of study is that it is a quick and cheap opportunity to study the problem in hand, but the disadvantage is that the population at risk is assessed over a narrow time frame. This means that the investigators cannot look at exposure and the resulting outcome over a longer period. The cross-sectional study therefore tends to be: • − Outcome-selective: the study examines the prevalence of a particular occupational condition within the population − Exposure-selective: the study examines a particular population which has been exposed to a specified occupational condition. Longitudinal studies These investigate the workforce over a significant period of time. The case-control study (retrospective) begins with a definition of a group of causes and relates these (along with controls) to the past exposure history. The follow-up study (prospective) takes a group of exposed persons (and possibly non-exposed controls) and follows them up over an appropriate time period to assess the eventual outcome of the exposure. Cohort studies are a specific type of follow-up study. Use of Epidemiological Studies There are five main uses of epidemiology in occupational health and hygiene: • Primary monitoring to identify hazards. Population studies are frequently the only way of identifying an occupational risk of disease such as lung cancer, coronary heart disease, varicose veins, or rheumatic disorders, because they are common in the general population. • Secondary monitoring to keep known hazards under control. Surveillance of a group of workers exposed to recognised hazards identifies any susceptible individuals and assesses the value of preventive measures and the effectiveness of control measures. • Determining causes helps to establish health standards. Studying groups of workers helps to determine whether ill-health is linked to exposure to a contaminant, i.e. a dust or vapour. This leads to establishing the cause and occupational hygiene standards such as occupational exposure limits (OELs). 2-16 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely • Community studies reveal how many people are affected and how seriously. Priorities can then be established enabling preventive action to be taken when and where it is necessary. • Evaluating health services to find out how they are used, their success in reaching certain standards and the value attached to them by the population they serve. Practical Application of Epidemiological Methods To be effective, an epidemiological study needs to follow six key steps: • Establish the objectives of the study and what hypotheses are to be tested. (Is disease A caused by agent B?) • Define the population being studied, bearing in mind statistical limitations of study and control group size • Prepare an action plan and any questionnaires required • Undertake a pilot study to test the approach and techniques are appropriate • Collect and analyse the data • Test hypotheses, record and report conclusions. The exact detail of the study will depend on the type of epidemiological investigation that is being performed. Limitations of Epidemiology There are of course limitations to epidemiology, including the healthy worker effect; a poor response rate; a high turnover of the study population; the time elapsed between exposure and effect being longer than the study period; the poor quality of data; and no effect of exposure noted, perhaps due to a poor or small study population. © RRC Business Training Section 2 | Reactive Monitoring 2-17 IOSH Managing Safely INCIDENT INVESTIGATION Theory of Accident Causation To manage safety effectively we have to identify some or all of the underlying causes. This session outlines the two basic approaches to determining accident causes. The multicausal theory implies that there are many factors (or sub-causes) contributing to accidents, and ultimately to injuries. The suggestion is that factors combine in a random way rather than in the logical, sequential manner suggested by the Domino Theory. Domino Theory H W Heinrich outlined one of the earliest theories of accident causation by saying that: A preventable accident is one of five factors in a sequence that results in injury. The injury is invariably caused by an accident and the accident, in turn, is always the result of the factors that immediately precede it. In other words, a preventable injury is the natural culmination of a series of events or circumstances that occur in a fixed logical order. He likened it to a row of dominoes placed on end so that if one falls over, it will strike the next and cause it to fall, and so on throughout the series. If one of the dominoes is removed, then the chain of events will be halted. Ancestry & Social Environment Fault of Person Unsafe Act or Condition Accident X Loss/Injury The Domino Theory The Injury Sequence If the injury sequence is interrupted by eliminating one of the factors in the sequence, it cannot continue and the injury will be prevented. Heinrich suggested that the most practicable factor to eliminate is the unsafe act and/or unsafe condition. 2-18 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely Because Heinrich was concerned essentially with a single causation approach to accident prevention, this tended to limit his theory's usefulness as its interpretation was narrow. However, Heinrich's Domino Theory can still be of use in accident causation identification as it enables the speedy detection of causes of accidents and allows prompt corrective action to be taken. Imagine an accident in which a person sustains injuries as a result of falling from a defective ladder. The Single Causation or Domino Theory would identify: Unsafe condition The defective ladder Unsafe act Using the defective ladder Corrective action Replace (or repair) the defective ladder Although this is helpful, we have to discover some or all of the underlying causes of the accident if we are to manage safety effectively. The multicausal approach, developed by Bird & Loftus, implies that many factors (or sub-causes) contribute to accidents and ultimately to injuries. This approach suggests that factors combine in a random way rather than the logical sequential manner which the Domino Theory suggests. A multicausal approach would prompt many questions about the ladder accident described earlier: • When was the ladder last inspected? • Why was the defect not noticed at the inspection? • Why did the supervisor allow its use? • Was the injured worker properly trained? • Was the worker aware of the dangers of ladders? • Was the injured worker properly supervised? When these questions are answered they will lead the manager to construct the following types of corrective action: • Improved inspection procedures • Improved defect-reporting procedures • Improved training for workers • Improved supervision of workers • Job safety analysis • Develop safe methods of work. © RRC Business Training Section 2 | Reactive Monitoring 2-19 IOSH Managing Safely Activity 2 Which of the following would you categorise as unsafe acts (A) and which would you say are unsafe conditions (C)? (i) (ii) (iii) (iv) (v) (vi) (vii) (viii) (ix) (x) (xi) Working without authority Missing machine guards Removing machine guards Excessive noise Defective tools and equipment Using defective tools Ignoring instructions Bad driving of fork lift truck Poor housekeeping Poor lighting Unauthorised servicing The answers to the activity are: unsafe acts (i), (iii), (vi), (vii), (viii), (xi); unsafe conditions (ii), (iv), (v), (ix), (x). Who Investigates Accidents? Minor accidents can be investigated by the supervisor with the help of the safety representative. The safety practitioner will investigate more serious accidents with the help of the manager, supervisor and safety representative. Immediate Supervisor Generally speaking, it is the immediate supervisor, that is the supervisor of the injured person or in whose department the damaged property belonged, who has certain qualifications which are possessed by no other member of the management team, including the safety officer: • The immediate supervisor is likely to know most about the situation and is therefore best suited to carry out enquiries necessary for an investigation to reach a satisfactory conclusion. • He should know his own people better than anyone else and probably knows more about how they act and think than they do themselves. • He also has a personal interest in determining the causes of an accident because accidents affect the efficiency and morale of his department. He is therefore in the best position to explain the consequences of work stoppage and personal injury to members of his production team. Familiarity with plant, equipment, and layout of the various operations will assist in recognising hazards that may have been overlooked for some time. But it must be remembered that unsafe acts, as well as physical conditions, contribute towards most accidents. It is not enough merely to 2-20 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely recommend fitting a guard while overlooking an unsafe act, such as rendering the guard ineffective or placing hands in the danger zone unnecessarily. It should therefore go without saying that it is equally insufficient to limit attention to an unsafe act if fitting a better guard would reduce the likelihood of injury. The Safety Officer In the case of serious accidents, the immediate supervisor may not have the necessary authority to conclude an investigation, and here the company safety officer should be in charge of the investigation. He should, however, seek the assistance of supervisory staff for the reasons outlined above. It is essential that the investigator has the authority to go as far as is necessary to get to the cause of the trouble. Activity 3 You are the manager of a warehouse. How would you collect evidence after a serious accident involving a forklift truck overturning with racking on a forklift truck? Select the most appropriate answer. (a) Inspecting the workplace and interviewing employees and the supervisor. (b) Interviewing the supervisor only and taking photographs for the Safety Officer. (c) Inspecting the workplace with the Safety Officer. (d) Interviewing employees and the victim and taking photographs. The answer to the activity is: (b) and (d) are perhaps less useful when considering people most at risk or involved in more accidents, their age (young trainees or older members of staff) might impact on the nature and causes of accidents. Investigation Procedure Finding out the cause(s) of accidents means that we can put things right and ensure accidents don't happen again. The investigation procedure has five key stages: • Immediate Response • Gather Evidence • Analyse the Information • Determine Accident Causes • Make Recommendations. © RRC Business Training Section 2 | Reactive Monitoring 2-21 IOSH Managing Safely Immediate Response The first responsibility must always be to the injured person. Resuscitation or first-aid must be carried out immediately by a qualified first-aider (where possible). All operations should then be made safe - systems turned off, valves closed - whatever is necessary to prevent further injuries or damage. This is usually the most time-consuming part of the process. Time spent on gathering information will contribute positively to preventing future accidents. Gathering Evidence You can gather the evidence by using: • Statements • Evidence • Measurements • Photographs. You can then go on to analysing the information. Analysing Information Analysing information really means being able to write down the story of the accident from start to finish. If this is not possible it will be necessary to go back and try to obtain more information, from witnesses or by examining photographs. At this point, where information cannot be found, the danger is that the investigator will make assumptions. It is so easy to do but should be avoided. It helps to reduce assumptions if at least two people are engaged on an accident investigation, which is where safety representatives can play an important role. The exercise of writing the story is useful because the information is always required to fill out the accident forms, both those of individual organisations or the Health and Safety Executive. Determining Accident Causes The big problem here is that people seldom report the causes of accidents; they report the causes of injuries. The cause of the injury is usually the last event in a chain. For example: • He cut himself with a knife • She tripped over a power cable. The causes of these accidents will be more complex than at first appears. When searching for the true causes of accidents you will find it useful to use the Four Absolutes of Safety: • Plant • Place • Competence 2-22 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely • System. Plant: He was using a knife for a job that demanded heavy-duty scissors. Place: She was working in an unsafe place with trailing power cables. Competence: He had not been trained to use the correct tools and was not being properly supervised. System: This indicates lack of inspection and supervision. She displayed a lack of awareness of the hazards which may be due to lack of training or motivation. Making Recommendations This is arguably the most important part of the investigation process. Once the causes of any accident have been determined it should be possible to make sensible recommendations to improve the situation and reduce the hazards in the workplace. Once again the Four Absolutes of Safety may be used to determine a list of recommendations: Plant: • Should new or different tools be used for the job in future? • Should protective clothing or equipment be purchased and issued? Place: • Should the lighting be improved? • Should the area be tidied before work commences? Competence: • Is more training necessary? • Is the level of supervision adequate? System: • Is the system of work clear and known to all? • Should the work be reorganised to improve safety? Finally, it should be stressed that recommendations should always be made without consideration of costs and in good faith. It is then the duty of senior management to consider seriously the recommendations made. Not all recommendations will be acted on, for reasons such as cost, practicability, available time, etc. Senior management should inform those making the recommendations of their decision and give reasons for not implementing them where this is the case. © RRC Business Training Section 2 | Reactive Monitoring 2-23 IOSH Managing Safely Activity 4 Identify whether the following statements are TRUE (T) or FALSE (F). (a) (b) (c) (d) (e) (f) Before you can determine the causes of an accident, you should first gather and analyse the facts. Where information cannot be found, the investigator is allowed to make assumptions. When making recommendations for improvements for health and safety, it is important for investigators to consider the financial costs to the organisation. When making recommendations, investigators should consider the four absolutes to safety: plant, place, competence, system. When gathering the facts about an accident, you should consider only the evidence. The causes of accidents are always straightforward. Injuries are usually the result of an accident, whereas accidents are due to unsafe acts or unsafe conditions. Answer: Only the answers to statements (a) (d) and (e) are TRUE. Types of Investigation Investigators can gather information in one of four ways: • By Inspecting the Scene It is important to preserve evidence exactly as it was found. Broken tools or personal protective equipment may all be required at a later date in a court of law. A routine investigation which is generally applicable or subject to suitable modification is as follows: Take a careful but detailed look at the scene of the accident from a distance, preferably from all sides, evaluating and noting the following points: − Extent and severity of the damage − Damage to surrounding property − Environmental conditions which may have had some bearing on the accident, such as temperature, ventilation, humidity and illumination. 2-24 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely Survey the accident site(s) to see if there are any obvious dangerous, physical conditions which may have been responsible for the accident. In the case of spillages, splashes or other escapes of toxic, explosive, flammable or other dangerous material, it may be necessary to take samples for subsequent laboratory investigation. Where machinery or other equipment has been involved, it may be necessary to issue instructions prohibiting the use or repair of it until the investigation has been completed. • By Interviewing Witnesses Any accident involves people but an investigation will not be simplified just because one or two people witnessed it. Often witnesses will be shocked. They may not wish to speak because the recall of the events is unpleasant. Others will cope with stress by making up or exaggerating facts. It is also easy to upset people when asking questions about what has been done, or indeed, what has not been done. But frequently, casual remarks made during a site inspection may be quite revealing and the investigator should talk to any personnel involved near the scene of the accident. This is an ideal opportunity to explain that the object of the exercise is to discover the causes and so prevent a repetition; it is not to apportion blame or to criticise any individual. • By Taking Measurements It is also important that if measurements are used in reports or in sketch plans they are physically performed and not just guessed. Working heights, widths, weights or light levels are all governed by legislation. If a guess is made at any measurement it could have the effect of depriving someone of compensation. DON'T GUESS IT - MEASURE IT! • By Taking Photographs The use of photographs is too easily overlooked after most accidents. They provide a very good record of the accident scene as it actually was and can assist people's memory. They can also be used to settle post-accident disputes. It is often difficult to describe an accident scene in words because there may be so many complex issues. Yet a couple of photographs could capture all the information. Remember, only snapshots are required and first consideration should be given to the injured party, not to the artistry of the photographs. In incidents involving complete or partial collapse or overturned containers, it may be beneficial to have photographic equipment available while the investigator directs clearing operations, as new evidence may come to light as rubble and fallen equipment is removed. An immediate record can then be taken of anything suspicious or informative which may be uncovered, before clearing activities destroy or damage the evidence in question. Also it is sometimes not clear, especially in confined spaces, which way up a photograph should be viewed or what the scale of it is. If this is likely, it is worth putting something into the picture (like a ruler with clear scale markings) to make it clear. © RRC Business Training Section 2 | Reactive Monitoring 2-25 IOSH Managing Safely Interview Techniques Witnesses should be allowed time to relax and gather their thoughts before answering questions. Safety representatives can play a very important role in this respect. Types of Witnesses Before considering various aspects of interviewing technique, we should first consider the three types of witness encountered: • There is what may be called the primary witness, the victim. Only that person will know exactly what the events were which led up to the accident and should be able to give a full account of his or her actions. Ideally the victim should be the first to be interviewed; after all, it was he who was directly involved. However, his injuries might be serious or he might be suffering from shock, and in such circumstances he should not be pressed for an explanation until he has sufficiently recovered. But in the case of less serious accidents or where there are no injuries or shock, then the worker directly involved should be questioned at the earliest opportunity. The general principles outlined above for interviewing any witnesses may be applied to the victim interview. • The secondary witness, extremely rare in practice, is the eyewitness; but how many people really see the instant of an accident? Usually their observation begins immediately or soon after the accident has occurred. • Finally there are what might be called the tertiary witnesses, those people who can offer a variety of corroborative statements regarding the acts of people or environmental information relevant to the circumstances surrounding the accident. Putting Witnesses at Ease The primary consideration is to put the person being questioned at ease by fully explaining the purpose of the investigation (i.e. to discover and root out the causes so as to prevent a repetition). The witness may be further relaxed by encouraging participation and involvement in the exercise. This can be done by showing interest in any ideas he or she might have about possible preventative measures. An understanding and friendly manner is essential in getting co-operation. Above all else, the witness must be assured that the purpose of the interview is not to blame anyone but to attempt to find out the cause and thereby to reduce the possibility of a recurrence. Interview Location If possible it is best to carry out interviews at the scene of the accident as it is generally easier for those involved to communicate effectively with the scene close at hand. It is usually much easier to explain clearly what happened if witnesses are able to point out specific things and recall their actions related to specific locations. Phrasing Questions Questions starting with WHY will only put the witness on the defensive and may even antagonise him and should therefore be avoided. Therefore a good principle to adopt in questioning witnesses is to start all questions following the pattern given below. 2-26 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely what WHAT happened? WHAT did you see? WHAT time was it? where WHERE were you at the time? WHERE was the victim? when WHEN did you realise something was wrong? how HOW did it happen? HOW were you involved? HOW could it have been prevented? who WHO else was involved? WHO else saw it? WHO reported it? Interview Questioning Attitude The question "What happened?" will often promote the fullest response and it is vital that the investigator listens, without interruption, to the witness's account of the accident. If something is not understood the investigator should wait until the witness has completed his account before asking him to clarify the point. The investigator should be after the witness's version of the accident and should not disagree with any statement or make judgments on his evidence alone. After all, what a witness believes to have happened will depend to some extent on just how he or she perceived the situation, even though this might conflict with the actual facts of the matter. Conclusion When each witness's account of the accident has been heard, the investigator should repeat it back to the witness to ensure the account is fully understood. This also allows the witness to hear his account and to add any details previously omitted or expand some points in order to make them clearer. When the investigator and the witness are both satisfied that a true account has been given, the interview should be concluded on a positive note, which is best achieved by discussing any ideas he might have regarding prevention of a similar occurrence. This will also serve to reaffirm the purpose of the interview and ensure the witness's further co-operation, should it be necessary. © RRC Business Training Section 2 | Reactive Monitoring 2-27 IOSH Managing Safely The Influence of Human Factors We have to examine the role of personal and human factors as an influence on both safe and unsafe working practices. It is not sufficient to dismiss an accident as being due to carelessness or ignorance. In order to comply with legislation (all of which is essentially a control on behaviour) we have to understand the different factors which influence the way people behave at work. Hale and Hale Model Hale & Hale developed a model of behaviour which shows the processes going on in the subconscious mind as people go about their activities. The model is a closed loop system which considers the following major factors: • Presented information: This is the actual information presented to the individual which their senses may or may not detect. This may be incorrect or incomplete and can be affected by such factors as individual physical problems and the layout of the workplace. • Expected information: This is what the individual expects to find based on past experiences and cultural frameworks. • Perceived information: This is what the individual actually believes that they see/feel/hear/sense and is a combination of presented and expected information, and is affected by secondary factors, e.g. effects of fatigue or drugs, physical or mental handicaps. • Possible actions can then be identified. • Each possible action will have a cost to the individual and a benefit. All outcomes are weighed through this cost benefit filter. It is worth emphasising that this is not a conscious process as the individual does not “think” about it. • The final action is then decided on and taken. • Action gives rise to feedback. The feedback may reinforce the behaviour, or cause action to be re-evaluated. Presented Information Perceived Information Possible Action Action Cost/benefit Decision Expected Information The Hale & Hale Model 2-28 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely For a simple example of how this works in practice, consider driving a car. Drivers are presented with thousands of items of information every second. They actually perceive only the bits relevant to their driving based on their past training/experience. They then decide on appropriate action (speed up, slow down, etc.) and take action. The action taken provides feedback (turn the wheel and the car turns too little, too much, just the right amount). Yet most of us can’t recall the drive to work the moment we step out of the car. The Hale and Hale model is important because it indicates how people might misinterpret information in the workplace and behave inappropriately in consequence. For example, a worker may switch off and isolate the wrong part of an electrical circuit despite the fact that he can see that the circuit is clearly labelled, because he has worked on many similar circuits in the past which were laid out the other way round to the present circuit. In other words, expectations (based on previous experience) override the presented information. In consequence the circuit is perceived incorrectly and the worker acts in accordance with his perceived information (what he thinks he sees). During accident investigation an appreciation of this model can help the investigator to determine those factors which might have caused inappropriate behaviour. This in turn can help with the identification of effective remedial action. Human Behaviour If we divide accidents into those attributable directly to human actions and those brought about by non-human causes, such as by machines, we find that 60 per cent of them may be attributable directly to some kind of human action. Almost 30 per cent of all reportable accidents result from handling goods. Many arise through neglect to look for sharp or rough edges and splinters on packing cases. Workers are generally unaware of the dangers until they sustain physical injury (what psychologists call "trial and error" learning). Similarly, many back injuries are caused by incorrect lifting techniques. Falling accidents, which account for a further 16.5% of the total, should be easy to prevent - ladders incorrectly sited, overreaching, unsafe scaffolding, slippery and untidy floors, and so on. The reasons for such accidents may best be understood by identifying three major human defects: © RRC Business Training Section 2 | Reactive Monitoring 2-29 IOSH Managing Safely Ignorance In law there is no excuse for ignorance of statutory legislation, but it is generally accepted that too few workers appreciate the dangers associated with their work. Some simply do not know or understand the dangers, others do not fully appreciate the consequences of their actions and how the safety of others may be affected. Remedy - training Carelessness Many workers are killed or injured, or cause others to be killed or injured, simply because they don't take care. They lack the necessary self-discipline to do the job in a safe way. Many of our safety regulations contain sections designed to ameliorate this human weakness. Remedy - Adequate Supervision Poor Communication Although human failings play a significant part in accident causation, a great deal can be achieved by ‘selling’ and publicising safety. Poor communication can be a contributory factor in accidents. Even careful, well-trained employees occasionally have accidents for a variety of reasons: distractions; poor concentration and piece-work for example. It should be the aim of the Safety Manager to foster safety awareness at all levels of the workforce and management team. This entails using every possible means of communication: a written safety policy; verbal reminders; safety committees and joint consultation; posters; films; safety surveys and audits; and exhibitions. Remedy - Meaningful Communication Behavioural Defects Psychological Factors Although accidents classified by primary cause may reveal differences between industries (especially between factories, and construction work; docks, wharves and quays; and inland warehouses) which reflect different physical environments and processes, they do not reveal the influence of personal attributes, such as: • Training • Experience • Fatigue • Medical, physiological and psychological factors. Attributing an accident to a single primary cause does not take into account the possibility of other contributory factors. Consequently, such simple classifications are of only limited use. In recent 2-30 Section 2 | Reactive Monitoring © RRC Business Training IOSH Managing Safely years, more and more emphasis has been placed on studying the psychology and sociology of accidents. Some of the findings are reviewed below: • Rest/Activity Cycles The adult human body runs on a 24-hour cycle of waking and sleeping. During shift work, the normal pattern becomes out of phase with work activities, leading to an increase in the accident rate towards the end of a shift. People do adjust their body-clocks to a different time slot, but it takes 10 to 14 days. Since this is often longer than a company keeps personnel on a particular shift, there are permanent highrisk periods for accidents on a shift work system. • Experience Analysis of accidents by age and/or length of service shows clearly the necessity of giving special attention to the protection of young persons and new entrants. Although the younger worker has a greater tendency to temporary disablement, his susceptibility to fatal and permanent disablement is not so high as for the older worker. This is probably because he is more agile, both mentally and physically, than the older person. Activity 5 Read the following statements and determine what category of human error is the likely cause of an accident. For each, select one option from the following three: (a) Carelessness; (b) Communication; (c) Ignorance. 1. 2. 3. 4. 5. 6. Spilt coffee is left on the stairs and a clerk slips and falls. A young employee traps his hand in a grinding machine which is left unattended during a shift change. A student employed for the holidays in a warehouse cuts his fingers on the sharp edges of a packing case. A despatch clerk strains his back while lifting some heavy parcels. Scaffolding is not properly secured with the result that a builder falls from a first floor building. A window cleaner breaks a leg falling form an old ladder. Answers: 1(a); 2(a); 3(c); 4(c); 5(a) and (c); 6(a) or (b). In fact, you might select all the options depending on the circumstances but generally common sense and attention to detail would prevent a good number of accidents. © RRC Business Training Section 2 | Reactive Monitoring 2-31 IOSH Managing Safely SUMMARY An accident investigation should include the following steps: • Discover the facts by carrying out an investigation as soon as possible after the event, checking the premises and taking photographs and measurements if appropriate • Question the witnesses • Identify the type of accident or incident and decide whether HSE or local authority officials have to be advised • Enter injuries in the accident book • Prepare a report analysing the accident and suggest recommendations to prevent a recurrence. The report should consider: • The working environment or conditions • The lack of safe systems of work • Unsafe or inadequate equipment • Lack of effective instruction or supervision • Unsafe personal or human factors. 2-32 Section 2 | Reactive Monitoring © RRC Business Training IOSH Certificate | Managing Safely C O N T E N T S Section Title 3 Page Risk Assessment and Risk Control 3-1 General Principles of Risk Assessment 3-2 The Meaning of Hazard 3-5 The Meaning of Risk 3-8 Workplace Precautions and Risk Control Systems 3-12 Summary 3-18 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 3 | Risk Assessment and Risk Control Learning Objectives When you have completed this section you should be able to: ! Define hazards and risks ! Describe the legal requirements for risk assessment ! Outline the principles behind risk assessment ! Demonstrate a practical understanding of quantitative risk techniques ! Identify data required for records Unit 3: © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-1 IOSH Managing Safely GENERAL PRINCIPLES OF RISK ASSESSMENT Legal Requirements of Risk Assessment Most health and safety regulations introduced in the UK specifically cover risk assessment. In general, they build on the philosophy originally formalised under the first Control of Substances Hazardous to Health Regulations COSHH) in 1988. Regulations which identify the need for specific risk assessment include: • Fire Precautions (Workplace) Regulations 1997 • Control of Substances Hazardous to Health Regulations 2002 • Health and Safety (Display Screen Equipment) Regulations 1992 • Manual Handling Operations Regulations 1992 • Noise at Work Regulations 1989 • Control of Asbestos at Work Regulations 2002 Although certain Regulations place an obligation on the employer to assess risks associated with specific hazards (e.g. hazardous substances, display screen equipment, manual handling), the Management of Health and Safety at Work Regulations 1999 (MHSWR) place a responsibility on the employer to determine all risks to which his employees are subject and to adequately control those risks. The Approved Code of Practice (ACoP) to the MHSWR gives practical advice on the risk assessment process. In brief it states that a risk assessment should: • Ensure that all relevant risks are addressed • Address what actually happens in the workplace or during the work activity • Ensure that all groups of employees and others (including visitors to the site) who might be affected are considered • Identify groups of workers who might be particularly at risk, for example young or inexperienced workers, those who work alone, and any disabled staff • Take account of existing preventive or precautionary measures. Risk Assessment Criteria A 'suitable and sufficient' risk assessment should: • Identify the significant risks arising out of work • Enable the employer to identify and prioritise the measures which must be taken to comply with relevant statutory provisions • Be appropriate to the nature of work and such that it remains valid for a reasonable period of time 3-2 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely • Assessments must be adequate. They must be sufficient to guide employers' judgments about the measures they should take to fulfil their legal obligations • Assessments must cover all risks to the health and safety of employees to which they are exposed at work • Assessments must cover risk to non-employees who may be affected by the employer's activities/operations, e.g. members of the public or contractors operating in the workplace • Whenever new or changed risks are encountered the employer must revise his original assessment. A regular review is advised as part of good management practice • Where employers employ five or more employees, the assessment must be in writing • Where groups of employees are especially at risk, those groups must be identified as part of the assessment, e.g. young, inexperienced or handicapped workers • In complex high-risk industries, where quantified risk assessment may be appropriate, the professional expertise of outside consultants may be required. Risk Assessment Process In all forms of Risk Assessment the process follows a similar format and includes: • Identification of situations or activities where the risk is considered to be 'not insignificant' • Identification of hazards associated with a situation or work activity • Identification of those who are exposed to the hazards • Identification of precautions currently applied • Evaluation of the risk associated with the hazard/activity • Determination of whether the level of risk is acceptable • If not, identification and introduction of additional precautions • A record of the findings so they can be brought to the attention of those who may be involved • A review of the assessments at regular intervals or when significant changes occur • Confirmation that the controls are being complied with, normally through some form of monitoring. This approach is not new to any of us. We practise it every day but don't consciously think about it. For example, if you want to cross the road, you don't just walk out on to the road: • You look both ways to identify the hazard (something which has the potential to cause harm), i.e. are there are any vehicles approaching? • You consider if there are any control measures in place which may reduce the risk of injury. Are there speed restrictions? Can the oncoming vehicles readily see me? • You assess the risk, i.e. you consider the speed of the vehicle and what the likelihood is of being injured © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-3 IOSH Managing Safely • If you have any doubt about the risk then you introduce additional safe practices. For example, you may let a vehicle pass before crossing or you may walk further along the road away from a blind spot or to a crossing where it appears safer. 3-4 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely THE MEANING OF HAZARD A hazard is something or some situation with the potential to cause harm. Risk can be considered as the likelihood that harm will result from the hazard (with some consideration given to the severity of harm that might result). Hazards can be visible and obvious, e.g. a fork lift truck. They can also be invisible and much less obvious, e.g. carbon monoxide gas, which is colourless, odourless and tasteless. Basic Workplace Hazards Hazards include: • Fire • Electricity • Water • Chemicals • Radiation • Micro-organisms • Biological agents • Working at height • Working in the sun • Working in confined spaces Although vehicles and machinery could be considered a hazard, it is useful to break them down into the mechanical and non-mechanical hazards associated with the equipment, e.g.: Mechanical Nonmechanical Impact Entanglement (rotating shaft) Crush Puncture Vibration Noise Fumes Heat Machinery Hazards We will discuss mechanical and non-mechanical hazards relating to machinery later. © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-5 IOSH Managing Safely Hazard Identification Techniques Since hazards can result in different forms of harm it is useful to record both the hazard and the harm. This will help us later on to focus on the workplace precautions that should be provided, e.g. head injury from falling object. Identifying hazards can be achieved by: • Viewing a situation or activity • Discussing with those involved in the activity • Referring to manufacturers’ or suppliers’ manuals or data sheets • Referring to a checklist of hazards as an aide-mémoire • Referring to accident/incident reports • Reviewing of HSE Guidance Notes (if a Guidance Note applies to a particular area then there are likely to be specific hazards associated with the work). Human Factors in Hazard Identification As the risk associated with a particular situation or activity will differ with the individual exposed to the hazard, it is necessary to acknowledge this within our assessment. Therefore an integral part of risk assessment is to identify the individuals or groups who may be particularly at risk. They may include: • Employees • Contractors • Young people (work experience trainees) • Expectant mothers • Members of the public • Those with language or literacy difficulties • Those with physical disabilities. Remember, we need only consider those who have a real likelihood of being exposed to the hazard. Basic Workplace Precautions We have to consider the precautions and control arrangements already in place to minimise the risk of injury from the hazard identified. At this point it is worth noting the difference between workplace precautions and risk control systems (RCS): • Workplace precautions (WPP) are those features, physical or systems of work, which are used to reduce the identified risk, e.g. machinery guards, operational procedures, personal protective equipment 3-6 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely • Risk control systems (RCS) are those systems required to ensure that workplace precautions continue to be effective, e.g. safety inspections, up-date training, system reviews, routine electrical testing, programmed maintenance. While many of the workplace precautions and risk control systems are obvious, others may be taken for granted and overlooked. If we consider the hazard of electrocution from an electrical appliance, it is likely that our list of workplace precautions and controls will include: • Staff prohibited from using equipment that is damaged • Staff undertake a pre-use inspection of cables and plugs • Equipment subject to programmed maintenance • Equipment is subject to an annual inspection and test for electrical faults. The electrical circuit into which the equipment is connected is in itself protected by a circuit breaker and this may well influence the risk rating allocated to the task. It acknowledges that, although the employee may be subject to an electrical shock, the effect or severity of the shock will be greatly reduced. Do not assume that if a workplace precaution or risk control system is documented in the manufacturer's operating book or your own organisation's method statements that this is how the operation is conducted. View the activity and speak to staff. It is only by determining what actually happens that a true and honest assessment can be completed. Activity 1 Which of the following would you consider as risks and which would constitute hazards? (a) Window cleaner climbs a ladder without anchoring it properly (b) Trailing cables in an office (c) Files piled on top of shelving (d) Typist removes a paper jam from photocopier without disconnecting the power (e) Secretary sprains her ankle falling over box of envelopes (f) Grinding machine does not have safety guard properly fitted Look around your own workplace and identify at least four hazards and four risks. Remember that a hazard is a condition or act with potential to cause harm or danger ((a), (b), (c), (d), (f)), while a risk is the likelihood and severity of harm caused, as in (e). © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-7 IOSH Managing Safely THE MEANING OF RISK Risk is the likelihood that harm will result from the hazard (with some consideration given to the severity of harm that may occur). Calculating Risk The Approved Code of Practice (ACoP) which supports the Management Regulations (MHSWR99) acknowledges that the time involved in assessing all risks can be significant and says trivial risks can usually be ignored. However, it then goes on to counsel a structured approach to risk assessment. With this in mind the first step is to: • Develop a list or inventory of situations or activities that occur within a discrete area of the workplace • Rank them in some form of order of the level of risk, e.g. low/medium/high. The ranking is likely to be subjective at first and should be reviewed at a later date. This approach helps us both to prioritise the higher risk activities and to provide evidence that the low risk activities have been considered, even though the process for them progresses no further. Risk Rating There are two distinct formats used to rate risk: QUALITATIVE Descriptors are used to inform the reader of the level of risk. In this situation combining the elements which influence the overall rating is achieved by reference to a descriptor matrix. QUANTITATIVE Numbers are used to reflect the level of risk. Although the quantitative approach must reference a range of descriptors, a simple mathematical calculation does allow us to focus more readily on hazards which require further controls. The level of risk associated with a particular hazard will depend on: • The probability, likelihood or frequency (all terms are used) that the hazard will result in harm • The severity of harm that results; and • The number of people likely to be injured. In many work situations, where the number of people likely to be injured in an incident is one, this element is omitted from the equation as multiplying by one will have no effect on the overall rating. This provides us with an equation where: Risk (rating) = Probability × Severity We will consider what these concepts mean and how they may be determined. 3-8 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely Probability/Frequency Rating • In high risk situations, where the number of people and the severity of injury are both likely to be high, physical tests which operate components and units to destruction are used to determine probability of failure. Complex mathematical models are also used to determine the effect of failure of individual components when combined with other components. • For activities of relatively low to medium levels of risk we must compromise between the cost (complexity of the exercise) and accuracy. For this reason many routine type activities of low to medium risk rely on the review of available data and subjective assessment. Accident and incident statistics, both company and national, will help to provide some guidance to arrive at a realistic assessment. Note that the number of people exposed to a hazard or a change in the environment or working conditions will influence the probability. Note also that the people whom you have identified as being at risk may affect probability. Adults in a factory environment do not routinely drink unlabelled liquids left on work surface. Children in a school or old people in a home may do just that because they are both less mentally aware. Probability can be expressed on a scale, ranging from improbable to frequent, with many intermediate descriptors. For the purposes of simplicity and clarity we will work with a scale of four points: 1 = Improbable (unlikely though conceivable) 2 = Possible 3 = Occasional (1 - 2 year) 4 = Regular occurrence. Now consider the probability of: • Getting run down by a vehicle while trying to cross a motorway at peak hour traffic • Crossing a street in a busy town • Crossing the street in a quiet cul-de-sac. If you consider that the scale is limiting and you feel that the probability lies somewhere between possible and occasional then use an intermediate number, such as 2.5. Severity Rating Accident and incident records, both company and national, will provide some guidance to help arrive at a realistic assessment. Take care to avoid the use of the worse case possible scenario, but accept the type of injury which is the worst foreseeable under the particular circumstances. A fall when on ground level might result in a trivial injury or may require first-aid, or might result in a broken bone while a fall from a height, i.e. a roof, is more likely to be fatal or disabling. You should take the worst case foreseeable injury in each case. Note that here also the people you have identified as at risk may also influence severity of injury. A fit, healthy 35 year old may break a wrist or finger falling on a level surface, whilst an elderly person may fracture a hip and never recover from the injury. © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-9 IOSH Managing Safely 1 = Trivial injury or damage to equipment 2 = Requires first-aid 3 = 'Minor', or a 3-day injury as classified by RIDDOR 4 = Disabling, fatal or multiple injury. Determining Acceptable Risk Levels The purpose of the rating is to help the assessor to evaluate the level of risk associated with a hazard and to prompt further action if appropriate. Whether we use descriptors or numbers, the function is to help us focus and to prioritise where action is required. Using the formula Risk (rating) = Probability (of occurrence) × Severity (of harm) and the above scales, action may be as follows: Risk (rating): 1-4 = Risk acceptable. No action necessary 5-8 = Further controls to be introduced 9 - 16 = Activity to cease until further work precautions and risk control systems are introduced. If we were to use the qualitative approach, then a matrix similar to the following example may be used to reach a conclusion: Likely Probable Possible Remote Improbable Fatal High High Medium Medium Low Major injury, permanent disability High Medium Medium Medium Low Minor injury Medium Medium Medium Low Low No injury/damage only Medium Low Low Low Low In a manner similar to that used in the quantitative approach, guidance notes indicating action for LOW, MEDIUM and HIGH results may be adopted. In both approaches, based on the above prioritisation of risk, it is possible to take the process a stage further to decide on action timescales. For example, the following may be relevant: 3-10 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely High Risk (9 - 16) Action must be taken immediately, as a matter of great urgency. If suitable control measures cannot be found immediately, the work should cease and not proceed until the risk has been reduced. Medium Risk (5 - 8) Action must be taken as soon as realistically possible to reduce the risk to as low a level as reasonably practicable. This could be sooner or later than, say, three months. Low Risk (1 - 4) It is not considered necessary to take action within the immediate future. However, some reduction in risk should be implemented within one year. Remember the rating is there to help us focus on where action is necessary, it does not preclude us from introducing additional controls, even though the risk is considered acceptable. Activity 2 In the following, identify the magnitude of risk as low, medium or high: (a) Trailing cable around a room (b) Boxes blocking access to stairs (c) Guillotine in use with improperly adjusted guard (d) Overloaded fork-lift truck (e) Boxes stacked against a wall in an unused part of the office (f) Coffee cup on computer desk (g) Oil spill in passage way (h) Worn carpet Remember that a risk is high where serious injury or fatality is likely. Control measures are deemed immediate and work should cease until problem is rectified. So, for example, you would class (b), (c), (d) and (g) as high risk. Medium risks are where injuries are likely or possible but will be of a minor nature. Action should be taken as soon as it is practicable to do so, i.e. (a) and (h). Low risks result when injury and damage are remote, i.e. (e), (f). © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-11 IOSH Managing Safely WORKPLACE PRECAUTIONS AND RISK CONTROL SYSTEMS If we consider the level of risk associated with a particular hazard unacceptable, we must identify additional workplace precautions and risk control systems in order to minimise the likelihood of injury or loss. Principles of Prevention The Approved Code of Practice (ACoP) reminds us that: ...the employer must implement what the assessment of risk has shown to be necessary to comply with 'the relevant statutory provisions' to reduce the risk to an acceptable level The Regulations provide an extensive list of 'Principles of Prevention' to be considered, which we can summarise as: • Avoiding risks • Evaluating those risks which cannot be avoided • Combating the risks at source • Adapting the work to the individual • Adapting to technical progress • Replacing the dangerous by the non-dangerous or less dangerous • Developing an overall prevention policy • Prioritising collective protective measures over individual protective measures • Giving appropriate instructions to employees. Hierarchy of Control Measures The principles can be translated into a “hierarchy of risk control measures”, which can be used during the risk assessment process to identify various possible actions available to combat a particular hazard in the workplace: • Eliminate the hazard, which is always going to be the most effective control, but may not be practical or possible in many situations. • Reduce the hazard at source, which tackles the hazard directly, by, for example, substituting one hazardous item with another less hazardous item. This is often used as a control method with hazardous substances. • Isolate people from the hazard, where we consider if it is possible to put distance between people and the hazard. Alternatively, can people be prevented from gaining access to the hazard by fencing or guarding the hazard in? 3-12 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely • Control the time or extent of exposure to the hazard. Some hazards do more harm the longer you are exposed to them. Therefore, limiting the time of exposure may be enough to bring the risk level down to an acceptable level. • Systems of work; adopting a safe system of work or safe working method may be crucial to risk control. • Personal protective equipment (PPE) may be used to protect individual workers. PPE should always be considered as a last resort because it protects only one person at a time and only protects properly if it is worn correctly and is of the correct fit, design and specification. The risk control hierarchy has the most effective measure at the top of the hierarchy and the least effective at the bottom. The lower down the hierarchy you move, the more difficult it becomes to ensure that control is always maintained and the more supervision and management becomes crucial to ensuring the success of the measure. If we return to our earlier example of trying to cross the road, our hierarchy of controls in order of preference should be: • Remove the hazard completely, as has been achieved within pedestrian precincts. • Avoid the hazard, for example by using a pedestrian-only bridge or underpass. Many risks can be reduced by separating hazards from people and vice versa. • If neither option is open to us, we can introduce a safe system of work; in our example it might be in the form of the 'green cross code'. • As an additional safety precaution, the use of personal protective equipment can be used to reduce the risk; in our example, a yellow fluorescent jacket. Don't forget the concept of 'so far as is reasonably practicable' (frequently referred to as ALARP 'as low as reasonably practicable'). This reminds us that where the risk is insignificant in relation to the cost in terms of time or money, then remedial action may be considered to be 'not reasonably practicable'. Reducing the speed of cars to 10 mph would not in many cases be considered as reasonably practicable. By the same token, if there is a control measure that can be introduced and would be relatively cheap, easy or quick to do so, then “so far as is reasonably practicable” requires us to put that control measure in place. As risk increases, so it becomes harder and harder to justify not putting extra controls and precautions in place. Compliance with Risk Controls It would be naive of any manager to assume that having completed the assessment and introduced appropriate controls that all employees will comply with company procedures. Regular monitoring and supervision will be essential to maintain the systems. Not only should we introduce the means of reducing the risk, we should also determine ways of confirming that the workplace precautions continue to be followed by introducing Risk Control Systems (RCS). They include: • Safety inspections, spot checks, supervision • Update training, safety bulletins/reminders • Safety notices/posters, warning signs © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-13 IOSH Managing Safely • Assessment reviews • Programmed maintenance/inspection/test. If you propose to introduce additional workplace precautions or risk control systems, it is important to identify who must take action and by when. Here are some examples of Workplace Precautions and Risk Control Systems: • Hazard: fire − Workplace precaution – a fire extinguisher − Risk control system: Annual inspection by a competent engineer Training for workers on correct use Weekly/monthly check to ensure the extinguisher is present, tagged and pinned • Hazard: moving part of machinery − Workplace precaution – an interlocked guard (hinged guard with a safety cutoff switch) − Risk control system: Daily safety inspection of the guard Training for the machine operator Planned preventive maintenance programme It is worth noting that the lower down the risk control hierarchy we move to select our workplace precaution, the more thought, time and effort we have to dedicate to the risk control system to ensure that the workplace precaution stays effective. Eliminate a hazard and it has gone for good. Introduce PPE and you will spend a lot of time specifying the correct PPE, ensuring good fit, buying and supplying, training, inspecting, cleaning, maintaining and supervising and enforcing its use. Recording Risk Assessment Results The Management of Health and Safety at Work Regulations 1999 (MHSWR) remind us that employers must record the significant findings of their assessments. In reality, assembling facts and details would be difficult without some form of documentation and guidance. The supporting ACoP reminds us that 'the level of detail in a risk assessment should be broadly proportional to the risk'. Providing a form contains the above elements, together with the following additional points, then most formats are considered as acceptable. The Hazard and Risk Assessment form addresses the main requirements for low to medium risk activities. Communicating Results Up to this point we have emphasised the importance of carrying out a risk assessment and recording the significant findings from it. The effort involved in carrying out the risk assessment will be 3-14 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely wasted, however, if staff are not made fully aware of the hazards and controls and if safe working practices are not maintained. Regulation 10 of the MHSWR requires employers to provide employees with comprehensible and relevant information on: • Risks to their health and safety identified by the assessment • Control measures in place and to be complied with • Procedures to be followed if there is serious and imminent danger. Where the risks associated with a particular situation or activity are considered to be relatively low, then the following suggestions of good practice should be considered: • Develop a 'master' file with a contents page • Group assessments in alphabetical order or under generic headings • Attach relevant HSE Guidance Notes or company procedural notes • Encourage staff to refer to the documents and provide personal copies to those involved regularly in medium/high risk work. Remember the practicalities associated with re-calling and re-issuing updated assessments. Ensure that your system is workable and that staff do not continue to follow outdated procedural controls. Risk Assessment Review Procedures Regular Assessment Reviews Having completed the assessments and introduced the necessary control measures, the Regulations require employers to review their assessments and work practices on a regular basis, or when significant changes occur which affect the level of risk. Such reviews should form part of standard management practice. © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-15 IOSH Managing Safely HAZARD AND RISK ASSESSMENT Assessment reference no.: Company Name: Department: Date of Assessment: Name of Assessor(s): Activity/situation assessed: Use of portable electrical equipment for office cleaning (vacuum cleaners & floor polishers) (Where activities are relatively low risk consider combining these to reduce repetition) Those at risk: Employees & visitors Hazard/Potential Injury: Workplace precautions/risk control systems: Electrical shock from poor insulation or damaged equipment. Staff prohibited from using equipment that has obvious signs of damage. Staff receive induction training on care and use of electrical equipment. Electrical appliances tested annually. Circuits fitted with residual current devices. Probability (2) × Severity (2) = Risk (4) Tripping from trailing leads. Probability (3) × Severity (2) = Risk (6) No apparent controls. Continue by listing hazard and potential injury Probability ( ) × Severity ( ) = Risk ( ) Recommended additional workplace precautions/risk control systems: Action by: Name: Date: Purchase equipment with automatic cable recoil at time of replacement Providing the control measures are complied with the assessor(s) consider that the risks identified with this activity are acceptable _______________ (Signature) Date of review: Probability: 1 = Improbable (conceivable but unlikely) 2 = Possible 3 = Occasional (1-2 year) 4 = Regular occurrence Severity: 1 = Trivial injury or damage to equipment 2 = Requires first-aid 3 = 'Minor' – 3-day injury as classified by RIDDOR 4 = Disabling, fatal or multiple injury Risk (rating): 1 - 4 = Risk acceptable. No action necessary 5 - 8 = Further controls to be introduced 9 - 16 = Stop activity until further precautions and risk control systems introduced Risk Assessment Form 3-16 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Managing Safely Activity 3 Select a specific area or department in your workplace or a workplace you are familiar with (i.e. this could be in a supermarket, warehouse, garden centre). In the form below: • Give a full description of the environment (i.e. outside, inside, big, small, with public access, etc.) • Identify five basic hazards and who might be at risk • Suggest what controls are in place • Categorise the risks according to whether they are low, medium or high. 1. Physical layout (i.e. Access and egress; lighting; etc.) 2. Activities carried out (i.e. nature of activities; maintenance; cleaning) 3. Machinery, equipment and vehicles (i.e. numbers involved; size of machines; power sources) 4. Chemicals and substances (i.e. nature of chemicals (e.g. cleaner, solvent, oil, etc.); likely amounts involved) © RRC Business Training Section 3 | Risk Assessment and Risk Control 3-17 IOSH Managing Safely SUMMARY A 'suitable and sufficient' risk assessment should: • Identify the significant risks arising out of work • Enable the employer to identify and prioritise the measures that must be taken to comply with the relevant statutory provisions • Be appropriate to the nature of work and such that it remains valid for a reasonable period of time. Assessments must: • Be adequate, giving sufficient detail to guide employers' judgements about the measures they should take to fulfil their legal obligations • Cover all the risks to the health and safety of employees to which they are exposed at work • Cover risk to non-employees who may be affected by the employer's activities/operations, e.g. members of the public or contractors operating in the workplace • Be in writing where an organisation employs 5 or more employees. Where groups of employees are especially at risk the groups must be identified as part of the assessments, e.g. young, inexperienced or handicapped workers. Whenever new or changed risks are encountered the employer must revise the original assessment. A regular review is part of good management practice. In complex, high-risk industries where quantified risk assessment may be appropriate, the professional expertise of outside consultants may be required. All risk assessments follow a similar process: • Identification of situations or activities where the risk is considered t be ‘not insignificant’ • Identification of hazards associated with a situation or activity • Identification of those who are exposed to the hazards • Identification of precautions currently applied • Evaluation of the risk associated with the hazard/activity • Determination of whether the level of risk is acceptable • If not, identification and introduction of additional precautions • Record the findings and bring these to the attention of those who may be involved • Review the assessments at regular intervals or when significant changes occur • Confirm that the controls are being complied with, normally through some form of monitoring. 3-18 Section 3 | Risk Assessment and Risk Control © RRC Business Training IOSH Certificate | Managing Safely C O N T E N T S Section Title 4 Page Health and Safety Legislation 4-1 Introduction 4-2 Criminal and Civil Law 4-3 Information Resources 4-7 Health and Safety Law 4-9 Advisory and Enforcement Bodies 4-13 Health and Safety Offences 4-18 Health and Safety Responsibilities 4-22 Summary 4-25 Appendix 4-27 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 4 | Health and Safety Legislation Learning Objectives When you have completed this section you should be able to: ! Differentiate between criminal and civil law ! Identify sources of health and safety advice and guidance ! Outline relevant health and safety legislation, codes of practice and guidance notes ! Describe the role and powers of advisory bodies and enforcement authorities ! Outline the prosecution and appeals procedures. Unit 4: © RRC Business Training Session 4 | Health and Safety Legislation 4-1 IOSH Managing Safely INTRODUCTION The starting point in any legal case is to decide whether it is a civil or criminal offence; the difference is between being prosecuted and punished for a criminal act or offence and being sued for a civil wrong by another to obtain compensation. An incident can lead to both a criminal and civil action; for example, a motorist may be prosecuted by the police for drunken driving (criminal action) and sued by an injured victim for loss of earnings (civil action). Here we will differentiate between criminal and civil law systems and outline the regulatory and enforcement processes relating to health and safety. As you read through this section, ask yourself what regulations will affect your company's specific operations. (A list of important acts and regulations can be found in the Appendix.) • Are copies of relevant statutes and regulations available in your workplace? If not, where might you expect to find the information you require on a specific issue? • Who should be able to advise you on the content and application of the law in terms of your company? 4-2 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely CRIMINAL AND CIVIL LAW Criminal Law Characteristics • Criminal Law is concerned with offences against the state and is designed to protect people, property and the environment • The source of law used in criminal cases is often statute law, that is Acts and Regulations created by Parliament • Prosecutions are generally brought by Government bodies, e.g. Police, HSE Inspectors • When bringing a prosecution there does not have to have been an accident or dangerous occurrence. It is enough for the inspector to see a breach of Act or regulations • Cases are heard in Crown Courts and Magistrate Courts • Penalties for non-compliance are imprisonment, fines or community service • Burden of proof is 'beyond all reasonable doubt' • Companies and individuals are unable to insure against sanctions imposed under criminal law. The processes involved in the introduction of both Acts and Regulations are shown in the figure below. © RRC Business Training Session 4 | Health and Safety Legislation 4-3 IOSH Managing Safely Elected members of Parliament Appointed Ministers of State Pass Create Acts of Parliament Entered in Statutory Instruments Statute Book (Statute Law) Laws created, e.g. Containing The Health & Safety at Work etc. Act 1974 Statutory Regulations Expanded by Management of Health & Safety at Work Regs. 1999 Provision & Use of Work Equipment Regulations 1998 The Creation of Statute Law Civil Law Characteristics • Civil Law is concerned with providing compensation to victims for damage to property, losses or injury • The source of law used in civil cases is often common law, that is the common law of the land as established by precedent, that is by custom and practice and previous decisions. It is documented in Case Law and not, generally, in acts and regulations • Cases are brought by private individuals • Cases are heard in High Courts , County Courts and Small Claims Courts. The structure of the court system is shown in the diagram below • The aim of the civil courts is compensation for the injured party, not punishment of the guilty • Burden of proof is 'on a balance of probabilities' • Companies and individuals are able to insure against claims brought under civil law. 4-4 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely JUDICIARY STRUCTURE − European Courts House of Lords Court of Appeal Criminal Division Jury determines guilt Judge determines Crown Court sentence, Prosecution v Accused Magistrates determine guilt and sentence, Prosecution v Accused Magistrates Court Court of Appeal Civil Division High Court Plaintiff v Defendant Claims over £50,000 County Court Claims between £5,000 and £50,000 Small Claims Court Claims less than £5,000 Claimant v Defendant The Court System in the UK © RRC Business Training Session 4 | Health and Safety Legislation 4-5 IOSH Managing Safely Activity 1 Look at the following definitions and identify whether they apply to criminal or civil law. Criminal Law Civil Law (1) Cases are brought by private individuals (2) Concerned with offences against the state (3) Designed to protect people, property and the environment (4) Cases are heard in High Courts, County Courts and Small Claims Courts (5) Uses statute law created by Parliament in the form of Acts and regulations (6) Prosecutions are generally brought by the Police or HSE Inspectors (7) Concerned with providing compensation to victims for losses or injury (8) Cases are heard in Crown Courts and Magistrate Courts (9) Companies and individuals are able to insure against claims (10) Penalties for non-compliance are imprisonment, fines or community service (11) Penalties are compensatory and court costs, not punishment Answer: Criminal law (2), (3), (5), (6), (8), (10); Civil law (1), (4), (7), (9), (11). 4-6 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely INFORMATION RESOURCES European Regulations and Directives Both European and UK legislation govern the Health and Safety legislative structure in the UK. European Regulations are set out in the form of Directives which identify standards to be achieved. The use of Directives allow Member States to decide how best to introduce these Regulations using existing legislative frameworks. Health and Safety Directives, developed by International Committees and Council Working Groups and ratified by the EEC Council, are enforceable under the Treaty of Rome, Article 100A (Standards) or 118A (Workplace Health and Safety). Regulations and Directives must be introduced into member states through their respective legal frameworks. Acts of Parliament are primary legislation, usually setting out a framework of principles and general means of implementation, e.g. the Health and Safety at Work etc. Act 1974 (HSWA). Acts must get approval of the 'Crown'. Regulations are secondary legislation made on the advice of the Health and Safety Commission (HSC) and tend to cover specific aspects relating to health and safety such as personal protective clothing or managing health and safety. These are enforced through Acts. Approved Codes of Practice (ACoPs) supplement Regulations and contain advice on requirements and implementation. There is no legal obligation to comply with an ACoP, but it would be necessary to demonstrate that standards had been achieved or that arrangements were equally effective. Guidance Notes are issued by the HSC or the Health and Safety Executive (HSE) and relate to specific topic areas, e.g. scaffolding. Again they have no legal status but courts will consider if arrangements have been 'so far as is reasonably practicable' by reference to the Guidance Notes as good industry practice. Lead Body Guidance Notes provide guidance to the courts, in the absence of ACoPs or HSE Guidance Notes, on what could be considered as good industry practice and as such will be considered as reasonably practicable. Legal Concepts Within legislation a number of phrases are used to determine standards. The following list identifies some in frequently use: 'Absolute' indicates that there is no choice and that standards must be achieved. This is normally identified within legislation by 'shall.......' or 'shall not .....'. 'So far as is practicable' indicates that standards must be achieved if there is a known danger and it is technically possible to protect against it. Again there is no balance of cost against risk. 'Reasonably practicable' indicates that where the risk is insignificant in relation to the cost in terms of time or money then remedial action may be considered to be not 'reasonably © RRC Business Training Session 4 | Health and Safety Legislation 4-7 IOSH Managing Safely practicable'. Note that it will be the responsibility of an accused person to prove that it was not reasonably practicable based on knowledge and frequency of occurrences prior to the accident. 'Best practicable means' lies somewhere between 'so far as is practicable' and 'so far as is reasonably practicable'. It indicates that the duty must be complied with by adopting the best solution available, in light of current knowledge and according to means and resources. 'Foreseeable' suggests that a particular event or situation could be predicted by someone with relevant experience or responsibilities. By ignoring a potential situation an employer or employee could not plead that the outcome was unforeseeable. 'Tort' is a particular element of civil law. The Law of Tort can be considered as ' ...a civil wrong and is subject to Civil Law action' and includes trespass, negligence, nuisance and defamation. 'Negligence' is one of the most frequent Torts cited in health and safety claims. In order to prove negligence, a claimant must show that: • A duty of care existed • There was a breach of that duty and • Damage or injury resulted from that breach - a claim cannot be brought if no loss resulted. 'Vicarious Liability' means that an employer is responsible for the actions of employees who are acting within the course of their employment. An employer would not be held liable for an employee caught speeding while delivering goods on behalf of the company. He would, however, be held liable for an employee who reversed through a customer's closed warehouse door. 'Duty of Care' emanates from the Tort of Negligence in that an employer owes a duty of care to employees and to others who may be affected by his undertakings. The standard of care that one person owes to another will vary depending upon the relationship, experience and disabilities. 4-8 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely HEALTH AND SAFETY LAW Health and safety legislation is introduced within the UK under Statute Law. In many health and safety cases Criminal and Civil Law operate together. If the defendant is proven guilty under criminal law and negligence has been shown, then a case for compensation brought by the injured party under Civil law is less difficult to prove (this is known as a “double-barrelled action”). There are many statutes and regulations regulating health and safety in the UK and the major ones are listed in the Appendix to this section. Health and Safety at Work etc Act 1974 The main statute regulating health and safety practice is the Health and Safety at Work etc Act 1974 (HSWA). It was introduced to improve health and safety standards across all sectors and with the intention of replacing existing legislation with a system of Regulations and an Approved Code of Practice (ACoP) providing detailed practical guidance on how to interpret the law. Failure to observe the Code of Practice is not an offence in itself, but can be taken into account in any legal proceedings. One example is the Approved Code of Practice for First-Aid at Work (Code L74, 1997, HSE Books). The objectives of HSWA are to: • Secure the health, safety and welfare of people at work • Protect people other than those at work against risks to their health and safety arising out of work activities • Control the keeping and use of explosives, highly flammable or otherwise dangerous substances. The Act is divided into four parts: • Part 1 Deals with general duties and enforcement (Sections 1 to 54) Part 2 Describes employment medical services (Sections 55 to 60) Part 3 Concerns building regulations (Sections 61 to 76) Part 4 Deals with assorted issues (Sections 77 to 85) HSWA imposes additional responsibilities or 'general duties' which are far reaching in effect although many are qualified by the phrase 'so far as is reasonably practicable'. This indicates that an assessment of risk must be compared to the time, work and expense of removing that risk. In other words, if the risk to health and safety is very low and the cost or technical difficulties are very high, then it might not be reasonably practicable to remove that risk. However, it is up to the person who creates the risk to show that it is not reasonably practicable to do something. Because it had been shown that 'people' were generally the cause of accidents, the emphasis of the legislation was moved from the workplace and equipment to safe systems of work. © RRC Business Training Session 4 | Health and Safety Legislation 4-9 IOSH Managing Safely • There are circumstances when the risk of injury is high unless certain steps are taken. HSWA has recognised this by placing an absolute duty on the employer to take specific steps to control hazards. The words used in the Act to indicate absolute duty are must and shall. When these words are used, there is no choice or evaluation of risk to be made by the employer. Taking cost into consideration is also not an option. • Employers, employees, self-employed, designers, importers, manufacturers and suppliers all fall within the scope of the Act and all are vulnerable if they fail to conform to it. An important point to note is that the Act does not extend to domestic servants or their employers as this would allow inspectors the right to enter private residential properties. • HSWA also provides HSE Inspectors with the power to issue Improvement Notices or Prohibition Notices (see later). These Notices are a distinct warning to the person concerned to rectify a certain situation or to stop work under certain circumstances. Failure to rectify a dangerous state of affairs may lead to prosecution, but the Notices at least give companies the opportunity to put things right before that point is reached. The Workplace (Health, Safety and Welfare) Regulations 1992 These Regulations expand upon previous general duties on employers and the self-employed to ensure, as far as is reasonably practicable, the health, safety and welfare of their employees at work. These Regulations should be considered together with the Management of Health and Safety at Work Regulations 1999 (MHSWR) which deal more specifically with assessments of risk. The main aim of the Regulations is to ensure that workplaces meet the health, safety and welfare needs of its employees which may include those with disabilities. They apply to most workplaces, including factories, offices, shops, colleges, hospitals, hotels and places of entertainment and are enforced under HSWA. They also apply to many outdoor sites such as car parks, access roads and pathways. Agriculture and forestry outdoor work sites which are some distance away from the organisation’s main buildings are excluded from the Regulations, with the exception of requirements relating to sanitary conveniences, drinking water and washing facilities, 'as far as is reasonably practicable'. The Management of Health and Safety at Work Regulations 1999 The principles embodied in the Management of Health and Safety at Work Regulations 1999 reflect the principles of duty of care owed by employers to employees and others. They formalise certain arrangements by which management will be required to show what they have done to provide and maintain safe and healthy working conditions by following efficient management practices. It places greater responsibility on the employer to determine the risks to which his employees are subject and to adequately control those risks. We looked at the duties relating to risk assessments and reviews earlier. Here, we will concentrate on the other duties relating to implementing health and safety in the workplace. Making Health and Safety Arrangements (Regulation 5) It has been obligatory ever since HSWA 1974 for companies to have a written Safety Policy (Health and Safety Policy) Statement which includes a description of the organisation and arrangements for 4-10 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely implementing the policy. The Approved Code of Practice (ACoP) spells out what arrangements should be covered and requires them to be recorded. They are: • Planning: Adopting a systematic approach which identifies priorities and sets objectives • Organisation: Putting in place the necessary structure to ensure safety performance improves and achieves set objectives • Control: Ensuring that decisions for promoting improvements are being implemented • Monitoring and review: Progressive improvements in health and safety matters can only be achieved through constant development of policies and in approaches to improved implementation and techniques of risk control. Seeking Health and Safety Assistance (Regulation 7) Assessments play a critical role but it is also recognised that competent assistance may have to be sought by the employer. "Every employer must have access to competent advice." This means having one or more persons who understand current best practice and know where to turn for more specialist advice. As time goes on, there will be formal recognition of various qualifications in health and safety but at present 'competence' means having 'sufficient training and experience or knowledge and other qualities' (ACoP) to enable appropriate advice to be given. Establishing Procedures for Serious and Imminent Danger (Regulation 8) Under Regulation 8 employers are obliged to establish and maintain procedures which should be followed in the event of serious or imminent danger to those at work on his premises. He is also required to nominate a sufficient number of competent persons to implement those procedures. Providing Information for Employees (Regulation 10) This Regulation reinforces Section 2.2c of HSWA in that employers have an obligation to inform employees of any significant risk identified by the assessment and to ensure that employees comply with the control measures put in place. © RRC Business Training Session 4 | Health and Safety Legislation 4-11 IOSH Managing Safely Co-operating and Liaising with Other Employers (Regulation 11) Where two or more employers share a workplace (temporarily or permanently), all those involved have to set up joint arrangements so that each and every party knows what all the others are doing in order that any risks may be dealt with. Depending on circumstances this may simply be a matter of the exchange of information between employers, but on a multi-occupancy site it may merit the appointment of a health and safety co-ordinator. Activity 2 Look at the different descriptions below and identify which one relates to: (i) Regulations (ii) Approved Codes (iii) Codes of Practice (iv) Guidance Notes (a) Expressions of opinion with no legal force, they nonetheless contain useful practical advice (b) Guides to good safety practice (c) Laws approved by Parliament and usually made under HSWA following proposals from the HSC (d) Failure to observe them would be considered negligent. Answer: (i) (c); (ii) (b); (iii) (d); (iv) (a). 4-12 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely ADVISORY AND ENFORCEMENT BODIES Although employers should observe health and safety law and regulations, not all do. Therefore a number of bodies have been set up to enforce the law and initiate proceedings against employers who infringe the law. Under HSWA, the main enforcing authorities are: • The Health and Safety Executive (HSE) which is split into a number of specific inspectorates e.g. Factories, Agricultural, Nuclear Installations • Local authorities through, principally, their environmental health departments; and • For certain matters, the Fire Authorities (Fire Services Act 1947). Although inspectors appointed under HSWA reinforce the law, they are authorised to do so by a written warrant from the enforcing authority. We will now look at the main enforcement authorities and the powers of the officers. Government Bodies A number of Government Bodies have been set up to provide advice and assistance in health and safety matters as well as to help enforce current legislation. The Health and Safety Commission Both the Health and Safety Commission and the Health and Safety Executive were established under Section 10 of the Health and Safety at Work etc Act 1974. The function of the Health and Safety Commission is to: • Assist and encourage persons in the furthering of safety • Arrange for and encourage research and the provision of training and information • Provide an information and advisory service • Submit proposals for regulations • Report to and act on directions from the Secretary of State. The Commission may direct the Executive, or authorise any other person, to investigate accidents, occurrences or other matters it thinks necessary and to make a special report. It is also the role of the Commission to approve and issue Codes of Practice, although it is not necessary for the Commission to prepare the Code of Practice itself. The Code cannot be approved by the Commission without the consent of the Secretary of State. The Health and Safety Executive The function of the Health and Safety Executive (HSE) is to make adequate arrangements for the enforcement of the relevant statutory provisions. It does so by appointing its own inspectors or by subcontracting the work to other agencies, such as a Local Authority in the form of Environmental Health Officers. Such bodies are referred to as 'Enforcement Agencies'. © RRC Business Training Section 4 | Health and Safety Legislation 4-13 IOSH Managing Safely In general, the HSE, through its inspectors, is responsible for enforcing legislation within higher risk industries, such as construction, manufacture and agriculture. It is also responsible for enforcing legislation within other enforcing authorities. The Local Authority, through its Environmental Health Officers, inspects and enforces health and safety legislation in areas such as offices, shops, catering organisations and residential properties. Employment Medical Advisory Service The Employment Medical Advisory Service (EMAS) was set up in 1973 as part of the Department of Employment and became part of the Health and Safety Executive (HSE) in 1975. EMAS is made up of medically qualified people whose job it is to study and advise on occupational health. It does not provide medical treatment. As well as advising the Health and Safety Executive itself, the main functions of EMAS are: • To help prevent work-related ill-health • To advise people who have occupational health problems on the type of work which will and will not suit them • To ensure appropriate biomedical input in the development of HSE policies and practices. Section 55 of HSWA provides for the continuance of this service, which has a duty to inform and advise the Secretary of State, the Health and Safety Commission and others concerned with the health of employed persons on matters concerning the safeguarding of health. Another function of EMAS is to provide information and advice on health to anyone in employment or seeking training for employment. EMAS provides an advisory service for the HSE on the occupational health aspects of health and safety Regulations and Codes of Practice. It will also give advice to employers, employees and trade unions who are concerned about particular work hazards such as noise, dangerous substances, etc. or on how occupational medical services can best be provided. EMAS liaises closely with the Department of Employment on the medical aspects of rehabilitation for employment and of training for and placing in employment. Enforcement Law Main Powers of Inspectors Under Section 20 of HSWA inspectors can: • Enter premises where they believe a dangerous state exists. A police officer may be taken along to help gain entry if required • Carry out necessary investigations and examinations • Direct that premises or part of them, or items within the premises, shall be left undisturbed for as long as required to make specialist examination • Take photographs, drawings and measurements of premises or items within them • Dismantle and/or test any item or substance which they consider harmful to health 4-14 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely • Serve Improvement Notices • Serve Prohibition Notices • Instigate criminal prosecutions. After an inspector has completed an investigation or examination, he has a duty to inform safety representatives of the actual matters he has found (Section 28(8)) and must give the employer similar information. Dealing with Cause of Imminent Danger We mentioned earlier that an inspector has the power to destroy things. Section 25 of HSWA gives him authority, in the case of any article or substance found by him in any premises which he has power to enter, and which he has reasonable grounds to believe is a cause of imminent danger or serious personal injury, to seize it and cause it to be made harmless, whether by destruction or otherwise. Before rendering it harmless the inspector must, if it is practicable for him to do so, take a sample of it and give it to a responsible person at the premises, having marked it for identification purposes. The inspector must also make a report on the matter and hand a copy of such report to a responsible person and, unless that person is also the owner of the article, serve a copy of the signed report on the owner as well. Obtaining and Disclosure of Information Occasions may arise when the Commission, the Executive, or an enforcing authority requires information in order to discharge its functions. Provision has been made for this in HSWA (Section 27). The Commission may, with the consent of the Secretary of State, serve on any person a notice requiring that person to provide the information requested. There are very strict rules regarding disclosure of information received under the provision of HSWA. The information must not be used for any purpose other than a purpose of the Commission or the Executive. No relevant information can be disclosed without the consent of the person by whom it was given (except where it is passed on to the Commission, the Executive, a government department or enforcing authority, and certain other authorities, e.g. a water utility, the police, or for the purpose of any legal proceedings or any investigation or enquiry held under Section 14 of HSWA). Dealing with Offences Enforcing officers may serve two types of notice on the employer: © RRC Business Training Section 4 | Health and Safety Legislation 4-15 IOSH Managing Safely Improvement Notices (HSWA Section 21) • Reasons for Notice An inspector may serve a notice on any person he feels is breaking one or more relevant statutory provisions, or is acting in such a way as to make it likely that contravention of the law will continue or be repeated. The inspector should state his reasons for the notice being served and ask for remedies to the situation within a specified period. • Period The period must not be less than the period within which an appeal against the notice may be brought, which is 21 days. Beyond that, the period allowed is left to the inspector's discretion and will be governed by the seriousness of the matters involved and the length of time and ease with which the necessary action can be taken to comply with the notice. • Action to be taken The notice may specify what action the inspector considers necessary to put matters right and may make reference to a Code of Practice or Guidance Note or British Standard. The notice may be issued for any activities to which relevant statutory provisions apply. • Person responsible An Improvement Notice is served on the person responsible for the breach of the law. If the law being breached imposes obligations on employers but the actual breach is by an employee then the notice is served on the employer. • Notice When intending to serve an Improvement Notice, the inspector must give two weeks' notice of his intention, to enable the recipient to make representations as to why the notice should not be served or to allow time for changes to be implemented. Prohibition Notices (HSWA Section 22) This more severe type of notice is issued where the inspector is of the opinion that the activities involve, or may involve, the risk of serious personal injury, e.g. a machine which is not adequately guarded. The Prohibition Notice must state that the inspector is of the opinion and specify the matters which give rise to the risk. It is important for the notice to direct that activities to which it relates must not be carried on by or under the control of the person(s) on whom the notice is served unless the matters specified in the notice have been remedied. Such direction will take immediate effect if the inspector is of the opinion that the risk of personal injury is or will be imminent. In any other case, it will have effect at the end of a period specified in the notice. A Prohibition Notice is served on the employer for whom the activities are performed. We can summarise the main differences between the two types of notice as follows: 4-16 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely Prohibition Notice Improvement Notice Served in anticipation of danger that the activities present a risk of serious personal injury. Served where a contravention of health and safety law exists and is likely to continue. Contravention of health and safety law does not necessarily apply. Activity does not have to be dangerous. © RRC Business Training Section 4 | Health and Safety Legislation 4-17 IOSH Managing Safely HEALTH AND SAFETY OFFENCES Under HSWA, directors, managers, company secretaries and similar officers of the body corporate have both general and specific duties. Breaches of those duties can result in individuals being prosecuted. We now look at the prosecution and appeals procedures in more detail. Who is Responsible for Offences? Offences Committed by Companies Section 37 of HSWA states: (1) Where an offence under any of the relevant statutory provisions committed by a body corporate is proved to have been committed with the consent or connivance of, or to have been attributable to any neglect on the part of any director, manager, secretary or other similar officer .... or a person who was purporting to act in any such capacity, he as well as the body corporate shall be guilty of that offence and shall be liable to be proceeded against and punished accordingly. (2) Where the affairs of a body corporate are managed by its members, the preceding subsection shall apply in relation to the acts and defaults of a member in connection with his functions of management as if he was a director of the body corporate. What this means is that senior members in the management of a company (as well as the company itself) may be liable individually for breaches of the law. The board of directors, individual functional directors and senior managers can all be prosecuted under this section. The issue of 'corporate manslaughter' and whether this applies to a company or organisation has long been a subject of debate in relation to health and safety. Sustaining a prosecution against individual directors is difficult because it cannot often be proved that an offence was committed with their consent or connivance or that it is attributable to their neglect. Where a director, manager, secretary or other senior officer of an organisation (corporate body) breaches or agrees to breach a relevant statutory provision, he as well as the corporate body shall be guilty of an offence, shall be liable to be proceeded against and punished accordingly. Generally, most prosecutions under HSWA Section 37(1) would be limited to that body of persons, i.e. the board of directors and individual functional directors, as well as senior managers. Three possible situations might apply depending on who commits the offence: • Board of Directors Where an offence is committed through neglect by a board of directors, the company and individuals may be prosecuted. 4-18 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely • One director Where an individual, functional director is guilty of an offence, he can be prosecuted as well as the company. • An Individual A company may be prosecuted even where an act or omission is committed by a junior official or executive or visitor to the company. Offences Committed by Other Company Personnel • Managers and supervisors Most companies delegate management functions to personnel, safety, training and works managers and other individuals. When offences are committed against HSWA and fall within the individual responsibilities of such persons, who is liable to be prosecuted - the individual, the company or both? Section 36(1) of HSWA states: Where the commission by any person of an offence under any of the relevant statutory provisions is due to the act or default of some other person, that other person shall be guilty of the offence, and a person may be charged with, and convicted of, the offences by virtue of this subsection whether or not proceedings are taken against the first mentioned person. This seems to suggest that the company, having delegated functions to another person, can escape prosecution in the event of an offence. However, in cases of strict liability, delegation of the function does not absolve the company from its vicarious liability. It will therefore be equally guilty of an offence committed by one of its employees. Where no strict liability is involved, and where there is no attributable knowledge, connivance or neglect by the company, the other person - the safety officer, works manager etc. - would be personally liable. In such cases, the individual manager may be found liable but proceedings are taken against the company. Perhaps the best way to understand its meaning is to refer to Section 36, which states: Where the commission by any person (a body corporate) of any offence is due to the act or default of some other person (the safety officer), that other person (the safety officer) shall be guilty of the offence and a person (the safety officer) may be charged and convicted of the offence whether or not proceedings are taken against the first mentioned person (a body corporate). Section 36 makes provision for dealing with offences committed by corporate officials; e.g. personnel managers, health and safety specialists, training officers, etc. Where an offence is committed under any of the relevant statutory provisions due to the act or default of some other person, that other person shall be guilty of the offence. That person may be charged with and convicted of the offence by virtue of this subsection whether or not proceedings are taken against the first mentioned person. © RRC Business Training Section 4 | Health and Safety Legislation 4-19 IOSH Managing Safely • Employees Employees are another category of persons who may be prosecuted under the Act. Section 7 of the Act states: It shall be the duty of every employee while at work: To take reasonable care for the health and safety of himself and of other persons who may be affected by his acts or omissions at work; and as regards any duty or requirement imposed on his employer or any other person by or under any of the relevant statutory provisions, to co-operate with him so far as is necessary to enable that duty or requirement to be performed or complied with. These are known as the general statutory duties of employees and, as they form part of a statute (HSWA), failure to comply is a criminal offence for which the employee may be convicted and fined. We will be looking at the general duties of employees later. • Prohibitions Section 8 of the Act states the no person shall intentionally or recklessly interfere with or misuse anything provided in the interests of health, safety or welfare in pursuance of any of the relevant statutory provisions. This prohibition extends to employees, supervisors and managers and means, for example, that it is a criminal offence to tamper with safety devices such as interlock switches. • Crown employees The final category of employer covered by some of the provisions of the Act is the Crown. Section 48 of the Act states that Sections 21-25 (Notices) and 33-42 (Offences and Prosecutions) do not apply to the Crown, which cannot be prosecuted. All the other requirements of the Act are binding on the Crown equally or on other employers. Crown employees may be prosecuted individually for any breaches of HSWA. Prosecution Proceedings for any offence under the Act can be commenced only by an inspector or with the consent of the Director of Public Prosecutions (DPP). In important or complex cases, the DPP may undertake the actual proceedings, particularly where the public good is concerned. Generally, minor offences are dealt with by the Magistrates' Court and serious offences are dealt with by the Crown Court. The determining factors are: • The gravity of the offence • The complexity of the case • The degree of punishment involved 4-20 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely Appeals Procedure for Appeal Appeals (HSWA Section 24) against notice must be submitted to an employment tribunal within 21 days of service of the notice. The tribunal may extend the time limit for appeal if it is satisfied that it was not reasonably practicable to appeal within the period. The appeal must be in writing and addressed to the appropriate secretary of the tribunals for England and Wales or Scotland. The appeal should explain why the notice is being challenged and give details of the premises and inspection carried out. Grounds for Appeal The main grounds for an appeal are: • Wrong legal interpretation by the inspector • The inspector has exceeded his powers • Breach of law is admitted but suggested remedy is not practicable or reasonably practicable according to the particular statute • Breach of law is admitted but insignificant For an Improvement Notice, the bringing of an appeal has the effect of suspending the operation of the notice until the appeal is heard or withdrawn. For a Prohibition Notice, the bringing of the appeal will have this effect if, but only if, the person appealing applies for the notice to be suspended and the tribunal so directs. One or more assessors may be appointed for the purposes of any proceedings brought before the tribunal. Contravention of the terms or requirements imposed by either a Prohibition or an Improvement Notice is an offence and may result in criminal proceedings being instituted against the offender by the inspector issuing the notice. © RRC Business Training Section 4 | Health and Safety Legislation 4-21 IOSH Managing Safely HEALTH AND SAFETY RESPONSIBILITIES The responsibility for implementing and enforcing health and safety procedures in an organisation does not rest with senior executives alone. All employees are deemed to be responsible for their own health and safety and that of others. However, without proper supervision, guidance and training from management, employees cannot be expected to carry out their functions efficiently. Here we look at the legal and moral duties placed on employers and employees when it comes to upholding safe working practices. As you read, reflect on whether there are clear reporting structures in your organisation: • Are staff aware of what their duties and responsibilities are in terms of health and safety? • Do staff know to whom they should report or comment on work conditions and practices? Who has Health and Safety Responsibilities? The Health and Safety at Work etc Act (HSWA) is by far the most important health and safety statute and governs virtually all occupations. The general duties and delegated powers contained in this Act provide protection for people at work and for the general public. It specifies duties of employers (including the self-employed), and of employees. Under HSWA (section 37), company directors, managers or other similar officers are guilty of any offence committed by a corporate body where the offence is proved to have been committed with the consent or connivance of, or to have been attributable to any neglect by those directors. Under the Management of Health and Safety at Work Regulations 1999 (MHSWR), employers and employees have absolute duties with regard to health and safety. Employer’s Duties Carrying out Risk Assessments Employers are legally obliged to make a suitable and sufficient assessment of the risks to their own employees and other persons affected by their activities. This should allow the employers to identify the measures they must take to comply with the requirements and prohibitions imposed on them by or under the relevant statutory provisions, i.e. other relevant health and safety legislation (similar provisions apply in the case of the self-employed). Implementing and Reviewing Safety Measures Among other obligations, the employer must also review and revise risk assessments, and implement changes where necessary; ensure the effective planning, organisation, control, monitoring and review of the preventive and protective measures; provide appropriate health surveillance; and appoint one or more competent persons to assist him in undertaking the measures he has to take in order to comply with the relevant statutory provisions. Appointing Responsible Persons We have seen that the law requires that people must be appointed to promote health and safety in the workplace, but it is important to stress again that those persons do not absorb any of the line 4-22 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely management responsibilities for health and safety. A common misunderstanding is that a safety adviser or officer is appointed to manage safety, leaving other managers to get on with their own important responsibilities for finance, production, etc. But health and safety is not an optional extra for managers; it is part of their role and of equal importance to their other duties. In many cases the person(s) appointed will be called a safety adviser, or some variant upon that term. For most small and medium sized companies, it will not be cost-effective to appoint a full-time safety adviser and for them the role may be combined with other duties. For even smaller companies it may not be possible even to do this and they will have to have recourse to specialist external consultants. However, whatever arrangement the employer makes, the MHSWR 99 will apply. Duty of Care The prime responsibility for health and safety lies with the employer, which means that management cannot delegate its health and safety liability. In the event of an accident or incident resulting in a court appearance, an employer might claim that he or she was incorrectly advised by a competent person, or that some inappropriate course of action led to a breach of duty. A competent person is someone who has sufficient training and experience or knowledge to enable him or her to assist in understanding health and safety measures. While a competent person may be criticised in the court's findings, it is relatively unusual for him or her to face charges under health and safety legislation, as liability is generally deemed to lie with the management. Employee’s Duties • Employees have a legal responsibility to take care of their own health and safety and the health and safety of others who may be affected by work activities and behaviour. This means not only avoiding reckless or stupid behaviour but also taking positive steps to understand the dangers and risks involved in the workplace, to comply with safety instructions and training, and to make sure that, by act or omission, they do not put others in danger. • Employees also have an obligation to co-operate with employers on matters of health and safety. For example, an employer has an obligation to supply, under certain circumstances, personal protective equipment to employees. Once issued with such equipment, and while engaged in the hazardous process for which the equipment was supplied, the employee must co-operate © RRC Business Training Section 4 | Health and Safety Legislation 4-23 IOSH Managing Safely by wearing or using the equipment correctly and in accordance with any instructions given by the employer regarding its use. • Employees are also covered by the general prohibition not to recklessly interfere with or misuse anything provided for health and safety purposes. Activity 3 Tick the correct response to each statement. 1. Employees have a duty of care (a) to take care of their own health and safety and that of others (b) to get to work on time whenever possible (c) to look after the workplace and equipment provided. 2. Employees must co-operate with (a) the police (b) the health and safety inspectors (c) their employer. 3. Where there is a breach of health and safety law, senior members of management are (a) liable as a corporate body (b) individually liable (c) not liable. 4. It is difficult to bring a successful prosecution against individual board members because (a) you cannot prove their negligence or connivance (b) they are not individually liable (c) only the director is liable. Answers: the correct responses are 1(a); 2(c); 3(b); 4(a). 4-24 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely SUMMARY • Criminal Law deals with enforcing health and safety legislation. Employers and individuals prosecuted successfully for non-compliance will receive a fine or a prison sentence. Prosecutions can also be brought for non-compliance with an Approved Code of Practice where it can be shown that no comparable precautions had been taken to protect against a risk. The Approved Code of Practice guidance would be considered as being 'that which is reasonably practicable' in most cases. • Under Civil Law, private claims can be brought by an individual who has suffered a loss. Awards are calculated as compensation to the claimant. Private claims can only be brought under the Tort of Negligence if it can be shown that a duty of care was owed to the claimant, there was a breach of that duty and loss or injury occurred. Organisations can insure against civil claims but not against criminal prosecution. The Health and Safety at Work etc Act 1974 is by far the most important health and safety statute and governs virtually all occupations. It was designed to encompass and replace virtually all existing occupational safety and health law. This process is not yet complete, which is why you will often encounter references to 'old' legislation; another reason for citing modified or repealed legislation is because of the body of case law associated with it. HSWA has eighty-five numbered sections and is divided into four parts. Part 1 deals with general duties and enforcement. The general duties and delegated regulatory powers provide protection for people at work and for the general public. There is a hierarchy of regulations and guidance published under the umbrella of HSWA, which deals with specific standards and problems; obviously, these will eventually become outdated by technological change, but they can be replaced by new regulations under the terms of the Act. The HSE Inspectors generally act in the capacity of the ‘enforcing authority’ for high risk industries with Environmental Health Officers (Local Authority) enforcing health and safety legislation within the lower risk industries. The Employment Medical Advisory Service was established to provide research and advice on occupational health and its problems. Enforcement of health and safety law regulations is covered by section 18 of HSWA. The main enforcement agencies are the Health and Safety Executive (HSE) who act for the Health and Safety Committee (HSC), local authorities and the Environment agency. Enforcement is mainly the responsibility of the HSE and the local authority. If an HSE Inspector feels that an employer is contravening one or more of the relevant statutory provisions, he may serve on him a notice stating that the contravention must be remedied within a specified period (Improvement Notice). If activities involve or may involve serious personal injury, the Inspector may serve Prohibition Notice with immediate effect on the person or persons carrying out the activities, whether or not that person is responsible for the legal liability. Inspectors have the power to remove or destroy articles or substances which they believe may be a source of imminent danger or which may cause serious personal injury. © RRC Business Training Section 4 | Health and Safety Legislation 4-25 IOSH Managing Safely Appeals against notices are covered by HSWA Section 24. Appeals must be in writing, giving details of the notice and grounds for the appeal. Proceedings for prosecution of an offence may only be started by an inspector or with the approval of the Director of Public Prosecutions (DPP). The main duties of employees under HSWA are as follows: • Take reasonable care of their own health and safety • Take reasonable care of the health and safety of other people who might be affected by their acts or omissions (things which they do and things which they fail to do) • Co-operate with their employer (on health and safety issues) • Not recklessly interfere with or misuse anything provided for health and safety purposes. In order to promote a positive safety attitude and compliance with the company policy and objectives, employees should be prepared to undergo training and be involved in discussing health and safety issues with their supervisors and managers. 4-26 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Managing Safely APPENDIX Main Statutes Disability Discrimination Act 1995 Employers’ Liability (Compulsory Insurance) Regulations 1969-1998 Fire Precautions Act 1971 Food Safety Act 1990 Health and Safety at Work etc Act 1974 Occupiers Liability Act 1984 Common Health and Safety Regulations Construction (Design and Management) Regulations 1994 Construction (Health, Safety and Welfare) Regulations 1996 Control of Asbestos at Work Regulations 2002 Control of Pesticides Regulations 1986 Control of Substances Hazardous to Health Regulations 2002 Electricity at Work Regulations 1989 Fire Precautions (Application for Certificate) Regulations 1989 Fire Precautions (Workplace) Regulations 1997 Food Premises (Registration) Regulations 1991 Food Safety (General Food Hygiene) Regulations 1995 Gas Appliances (Safety) Regulations 1992 Gas Safety (Management) Regulations 1996 Health and Safety (Consultation with Employees) Regulations 1996 Health and Safety (Display Screen Equipment) Regulations 1992 Health and Safety (First-Aid) Regulations 1981 Health and Safety (Safety Signs and Signals) Regulations 1996 Lifting Operations and Lifting Equipment Regulations 1998 Lifting Plant & Equipment (Records of Test & Examination) Regulations 1992 Management of Health and Safety at Work Regulations 1999 Manual Handling Operations Regulations 1992 Noise at Work Regulations 1989 Personal Protective Equipment (PPE) at Work Regulations 1992 Provision and Use of Work Equipment Regulations 1998 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 © RRC Business Training Section 4 | Health and Safety Legislation 4-27 IOSH Managing Safely Safety Representatives and Safety Committees Regulations 1977 Special Waste Regulations 1996 (SI 1996 No. 972) Working Time Regulations 1998 (SI 1998 No. 1833) Workplace (Health, Safety and Welfare) Regulations 1992 4-28 Section 4 | Health and Safety Legislation © RRC Business Training IOSH Certificate | Managing Safely C O N T E N T S Section Title 5 Page Management of Common Hazards 5-1 Maintaining Safe Working Conditions 5-2 Workplace Hazards 5-8 Fire Principles 5-11 Fire Risk Assessments 5-16 Evacuation Procedures 5-22 Electricity Hazards 5-28 Manual Handling 5-34 Mechanical Handling 5-40 Hazardous Chemicals 5-42 Display Screen Equipment 5-47 Noise at Work 5-52 Summary 5-56 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 5 | Management of Common Hazards Learning Objectives When you have completed this section you should be able to: ! Describe the main requirements of the Workplace (Health, Safety and Welfare) Regulations and associated codes of practice. ! Identify common workplace hazards and types of controls and precautions. Unit 5: © RRC Business Training Section 5 | Management of Common Hazards 5-1 IOSH Managing Safely MAINTAINING SAFE WORKING CONDITIONS Irrespective of the workplace in which you work there are likely to be a wide range of hazards, many of which we take for granted such as the movement of vehicles. A number of the potential hazards have been 'designed out' but the highest risks are still those associated with the maintenance and repair of buildings and fittings. Of particular concern is working at height and in confined spaces. The Workplace, (Health, Safety and Welfare) Regulations 1992 and Approved Code of Practice came into force in two stages. The Regulations took effect for all work buildings on the 1st January 1996 and are enforced under the Health and Safety at Work etc. Act 1974. The Regulations apply to the majority of workplaces including factories, offices, shops, colleges, hospitals, hotels and places of entertainment. They also apply to many outdoor situations such as car parks, access roads and pathways. Agriculture and forestry outdoor work sites which are some distance away from the businesses main buildings are excluded from the Regulations, with the exception of the requirements relating to sanitary conveniences, drinking water and washing facilities, 'as far as is reasonably practicable'. Like HSWA, the Workplace Regulations apply to all employees and to the self-employed. The main aim of the Regulations is to ensure that workplaces meet the health, safety and welfare needs of its employees and that includes those with disabilities. The Workplace Regulations constitute good practice, replacing much old legislation, and should not be considered in isolation. In particular they should be looked at together with the Management of Health and Safety at Work Regulations 1999 with assessments of risk brought about by the use or maintenance of the workplace being considered. They cover three specific aspects of the workplace: • Environmental working conditions • Welfare and amenity provisions • Structural safety Environmental Working Conditions Ventilation (Regulation 6) The ACoP relates to the provision of fresh or purified air but does not include aspects relating to the removal of hazardous substances by means of ventilation as they are covered under COSHH. Efforts should be made to prevent employees being exposed to draughts. Workstations may have to be resited or screened. Insufficient fresh air in the workplace may lead to tiredness, headaches, eye irritation, so it is important for employers to provide enough fresh or purified air in the workplace. A major problem associated with air-conditioning is the presence of water cooling systems, which, if not maintained properly, may become a breeding ground for the Legionella bacterium which can cause serious flu-like symptoms. 5-2 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Temperature (Regulation 7) The temperature in workrooms would normally be at least 16°C unless much of the work involves considerable physical effort, in which case it should not be less that 13°C. Excessive cold or hot conditions can seriously affect work levels and efficiency. One exception is where it would be impractical to maintain such temperatures, i.e. in an open-sided building or where food or other perishable produce are stored. Localised heating and the prevention of draughts are but two alternative measures which may be taken to prevent discomfort. Thermometers must be available to measure the workplace temperature. Lighting (Regulation 8) The form and level of lighting has not been set. The legislation states that lighting should be 'suitable and sufficient' with the level being dependent on the type of work and the possibility of tripping. Where there are windows they should be kept clean and clear of obstructions to allow the maximum natural light to enter. Where the sudden loss of light is likely to result in a high risk to injury, then emergency lighting may have to be installed. Fire legislation may require emergency lighting. Cleanliness (Regulation 9) It is accepted that the standard of cleanliness will vary with the use of the workplace, but all surfaces must be kept sufficiently clean. Hazards likely to cause slips, trips or falls must be eliminated. Where refuse or dirt accumulates anywhere other than in suitable containers, it must be removed daily or more frequently if necessary. The inside of buildings must be constructed of materials and in a form that can be kept sufficiently clean and be cleaned at regular intervals. Room Dimensions (Regulation 10) This Regulation deals with room dimensions and space and does not normally pose a problem, but it may create difficulties for overcrowded offices or factories. The volume of a room, when empty, divided by the number of people normally working in it should not normally be less than 11 cubic metres. There are of course exceptions, such as machine control cabs, kiosks, lecture and meeting rooms. Note that in calculating room volume any part higher than three metres must be ignored. Workstations (Regulation 11) Regulation 11 reminds us that workstations should be so arranged that tasks can be carried out safely and comfortably. Seats at workstations should be adjustable, provide support for the back as well as adequate space for free movement and allow the operator to stand if s/he so wishes. Conditions of Floors (Regulation 12) Vehicular and pedestrian routes must not create a risk to health and safety, i.e. holes, angle of slopes, uneven and slippery surfaces. © RRC Business Training Section 5 | Management of Common Hazards 5-3 IOSH Managing Safely Welfare and Amenity Provisions Regulations 20-24 state that employees should be provided with a good standard of welfare and comfort such as: • Suitable drinking water • Toilet and washing facilities normally with running hot and cold, or warm water • Accommodation for changing and storing clothing where appropriate • Facilities for warming food as well as a place to eat it • Rest facilities for pregnant and nursing women. Structural Safety Under Section 5 of the Regulations, an employer is required to maintain facilities to a safe standard. This can best be achieved through the introduction of routine maintenance schedules and regular monitoring inspections. Where facilities fail to meet the standard and are likely to result in danger, a record of the results of both inspections and maintenance must be kept. Safe Systems of Work Maintenance of buildings and associated facilities sometimes leads to tasks which are likely to place maintenance staff in high risk situations. It is therefore important that Risk Assessments are conducted and that Safe Systems of Work are introduced. Examples of maintenance jobs involving risk of serious personal injury and requiring safe systems of work include: • Cleaning windows or roof gutters • Replacement of light bulbs and tubes, particularly those in high ceiling buildings • Entry into confined spaces, e.g. vessels, tanks, drains and ducting • Repairs or replacement of electrical equipment/Work on or near overhead power cables. 5-4 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Permits-to-Work Some maintenance or building jobs may require a Permit-to-Work. This document specifies the task to be performed and instructs how it is to be carried out in a safe manner, the procedure being based upon all the foreseeable risks. There are five main steps to achieve an effective permit-to-work system: 1. Evaluate Hazards This entails identifying every type of hazard that may be encountered, and devising a means of eliminating or overcoming them. 2. Planning Precautions All planning associated with the permit must be carried out by a competent person of authority who should have sufficient detailed knowledge of the hazards of the premises or plant, such that he can formulate the plan properly. He should have an adequate knowledge of the legal requirements and of the technical terms, such as isolate, lock off, and blank off, as they apply to the permit-to-work system. 3. Instructing Supervisors It is important that the person issuing the permit carefully briefs the people who will carry out the work. The instructions in the permit must be fully understood, which can best be achieved by direct questions and answers to supplement the written work. 4. Issuing the Permit The issuer should complete and sign the permit and give it to the person in charge of the work. Sufficient copies must be given to any site managers and supervisors involved, especially where it is necessary for them to be kept informed of work progress. An additional copy of the permit should be exhibited nearby during the time it remains in force. 5. Closing the Permit On completion of the work, the manager responsible for the issue of the permit should confirm that all the procedures have been carried out correctly, that the work has been completed, that all staff are accounted for and that the facilities are in a safe condition. Only when careful checks have been made should the permit be signed off. © RRC Business Training Section 5 | Management of Common Hazards 5-5 IOSH Managing Safely Entry into Confined Spaces When we consider entry into a confined space such as a drain or ducting, the associated hazards may include lack of oxygen or presence of toxic gases. In this situation, the permit to work/safe systems of work should include testing the atmosphere before entry and for the duration of the work; availability of rescue/emergency equipment (development of an emergency plan); presence of an experienced, responsible person. There are normally supporting Regulations for work of a particularly high risk, e.g. the Confined Spaces Regulations 1997. Such tasks should not be attempted unless staff are well trained and safe systems of work are adopted. Rescue measures must be put in place before any confined space entry work is undertaken. All too often emergency rescue procedures are not thought out and as a consequence poorly prepared staff will try to rescue their workmates if they get into difficulties. There are often multiple fatalities during confined space entry accidents for this reason. If you are in any doubt, you should use specialist contractors. 5-6 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 1 1. Which of the following facilities are not covered by the Workplace (Health, Safety and Welfare) Regulations 1992? (Tick the appropriate responses.) (a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) 2. Factories Offices Shops Colleges Hospitals Hotels Places of entertainment Agricultural land Forests Outdoor work sites Car parks Access roads Pathways List the FIVE key stages of a Permit-to-Work: (a) (b) (c) (d) (e) 3. Which of the following can arise from a poor working environment and poor housekeeping? (Tick the appropriate answers.) (a) (b) (c) (d) (e) (f) Slips , trips and falls Inconvenience Eye strain Blood pressure Back ache Overheating Answers: 1. (h), (i), (j). 2. Hazard evaluation, precaution planning, instructing the supervisors, issuing the permit, closing the permit. 3. (a), (c ), (e), (f). © RRC Business Training Section 5 | Management of Common Hazards 5-7 IOSH Managing Safely WORKPLACE HAZARDS Every year in the UK about 400 people are killed in work-related accidents and over a million workers are injured. The cost of accidents and ill-health to industry equals £140-£300 per worker employed. While accidents will vary in terms of severity, with some industries such as construction incurring bigger losses, a number of accidents and incidents are quite commonplace. The Workplace (Health, Safety and Welfare) Regulations 1992 provide guidance on what precautions employers must take to prevent or minimise accidents at work. Falls and Falling Objects (Regulation 13) Fences should be provided where a person could fall a distance of 2 metres or more or where there is a risk of serious injury due to a fall. Fences, as a minimum, should have two guardrails with the top rail being at least 1.1 m high. Un-tensioned chains or ropes would not be considered as appropriate. Ladders which are used regularly in the same place should have the facility provided to secure them. Where access is infrequent and where it is not considered as reasonably practicable to erect fences or barriers to prevent falls, fall arrest systems may be an acceptable second choice. Fall arrest systems do not prevent falls but do minimise injury through limiting the distance of a fall. Equipment consists of a harness and rope connected to a recoil mechanism which automatically limits any sudden extension of the rope, rather similar to that of a car seat belt. Eye bolts or other secure anchor points must be provided for their use. Windows, Doors and Walls (Regulations 14-16) Regulation 14 highlights the requirement to mark clearly the position of glass panels and to construct them of suitably strong material. All glass features used in building construction should be surveyed to identify panels which must be replaced or laminated with plastic film, so that in the event of breakage they minimise harm. Windows and other means of ventilation should not in themselves create a risk when opened. Provision must also be made to ensure that staff and others are not put at risk when windows are being cleaned. 5-8 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Movement of People and Vehicles (Regulation 17) Transport and other vehicles present one of the greatest risks of injury to people and damage to plant or buildings. Of the many fatal accidents that occur each year involving the use of transport within sites, the most common type involves victims who are struck or run over by vehicles. Pedestrians Where possible, specific routes should be provided for pedestrians with the aim of segregating people and vehicles: • Where appropriate, pedestrian routes should have designated crossing points over roads and suitable barriers at entrances to and exits from buildings to discourage pedestrians from walking directly into the road • In areas where traffic is particularly busy, bridges or subways may be appropriate • Where vehicles pass through doorways or other pinch points where there is insufficient width to allow vehicles and pedestrians to be separated by a raised or railed off footpath, then separate access for pedestrians is helpful. Vehicles Road layout and design should be arranged clearly and logically, allowing adequate space for movement, reversing, turning, loading and off-loading. Roads should be wide enough for the safe movement of the largest vehicle likely to use them, with allowance made for visiting vehicles which may be larger than those used exclusively on site: • White lines are required to divide access roads into lanes, to indicate priorities at junctions and to mark the boundaries of parking and loading bays • Hazards such as sharp bends and blind corners should be eliminated where possible; suitable warning signs and mirrors can reduce the risk • As far as possible the need for vehicles to reverse should be eliminated by the use of clearly marked one-way systems • Physical protection of vulnerable plant and equipment such as storage tanks, pipe work and storage racking may be necessary • Adequate lighting is necessary, particularly where there is regular movement of vehicles and other mobile plant and in pedestrian areas • Speed limits should be set and enforced on sites. As enforcement is often difficult, speed retarders (such as humps) accompanied by prominent warning notices can be used to prevent vehicles being driven at excessive speeds. They can however, introduce, additional hazards if used by fork-lift trucks • Sufficient and suitable parking areas should be provided for all vehicles, including employees transport, visiting cars, cycles, waiting goods vehicles, sites for skips and pallet stacks. © RRC Business Training Section 5 | Management of Common Hazards 5-9 IOSH Managing Safely Vehicles Reversing A large number of people are killed and injured every year as a result of being knocked down or trapped by vehicles reversing. Many of the accidents occur when lorries reverse into loading bays. As many such incidents occur at low speed, accidents could be avoided if reasonably practicable precautions are taken. One such precaution is the use of a person to guide the vehicle back during reversing operations. It is essential that the nominated person is trained in how to guide reversing vehicles in order that they do not put themselves or others at risk. Doors and Gates (Regulation 18) Large doors and gates, particularly those which are powered, must be so designed to prevent them falling off their track or from crushing the user, either when closing or falling down if they are raised to open. A window must be inserted in doors which are capable of being opened in either direction. Escalators and Moving Walkways (Regulation 19) It is recognised that there is the potential for clothing or goods to become trapped in any form of mechanism and as such emergency stops must be fitted. The construction and maintenance of lifts in the workplace are covered by the Lifting Operations and Lifting Equipment Regulations 1998 and as such are subject to programmed maintenance and testing. Activity 2 1. List FIVE workplace precautions which can be used to minimise the risk of injury to pedestrians from moving vehicles. (a) (b) (c) (d) (e) Answer: Your answer might include one-way systems, speed retarders or restrictions; good lighting; clear road markings; adequate parking bays. 5-10 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely FIRE PRINCIPLES Every year approximately 900 people are killed and 10,000 more are injured in fires. More than half of those who die in this way do so because of the effects of toxic, choking smoke and not - as is generally supposed - because they actually get burned to death. This can happen if escape routes are barred or blocked off (as happened in the Bradford City fire) but more likely than not, victims get burned because they have already succumbed to the fumes or become disorientated by smoke (as happened in the Manchester Airport fire). From such appalling statistics - not to mention the annual cost to industry - it is clear that all possible steps to prevent fire breaking out should be taken. If this fails it is essential that the risk to life be absolutely minimised. The Combustion Process For a fire to start or spread (i.e. combustion), three essential elements have to be present: fuel or a substance which can burn. This may be solid (e.g. paper), liquid (e.g. petrol) or gas (e.g. propane). oxygen - usually in the form of air, which contains 20 per cent oxygen. heat - the temperature must reach a certain level. This might take the form of a spark (from a match or friction from a tool striking stone) or a spontaneous build up of heat, such as can occur in grain silos. These three components are frequently referred to as the Fire Triangle. Remove any one of those elements and the fire cannot burn. Fire-related Hazards The main hazards associated with fire are: • Toxic fumes produced by combustion • Smoke causing suffocation and loss of visibility • Burning by heat or flames • Suffocation due to depletion of oxygen within the atmosphere • Collapse of building or structure due to failure of materials. © RRC Business Training Section 5 | Management of Common Hazards 5-11 IOSH Managing Safely Fire Spread Heat always travels from areas of high temperature to areas of lower temperature. Heat is transmitted in three different ways. Conduction Conduction involves heat energy passing through (normally) a solid. If, for example, the end of a poker is held in a fire, heat will travel up the metal rod until the handle becomes hot. Metals are generally good heat conductors, whereas non-metals, glass, plastic, wood, rubber, are insulators. Fire spread can take place by conduction through a steel door or along a steel beam. Casing the latter in insulating materials will significantly reduce the rate of heat transfer. Convection Convection occurs only in liquids and gases. When a liquid or a gas is heated, it expands and therefore becomes less dense. The lighter fluid rises by being displaced by colder and therefore denser fluid. This in turn becomes heated and so a circulation of heat is set up. Heat energy is carried throughout the fluid by actual movement of molecules until a state of uniform temperature is reached. In a fire, convection allows fire to spread to the upper storeys of a building due to hot gases rising up lift shafts and stairwells. Radiation Radiation is the transmission of heat by invisible rays from a hot object. The rays can travel through air and through a vacuum but are stopped by solids and liquids. The heating effect diminishes with distance. Materials allowing the rays to pass through without any heating effect are transparent. Many other materials either absorb the radiation and heat up or reflect it. The best reflectors are shiny or white smooth objects. Blackened objects do not reflect well but do radiate heat more easily. Clothes hanging near an electric heater for drying are an example of how a fire may spread by radiation. 5-12 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Fire Classification Fire can be divided into roughly four categories: Class A fires are freely burning fires in wood, paper, textiles or any other ordinary combustible material. Cooling with water is the most effective medium for extinguishing this type of fire. Class B fires involve flammable liquids such as alcohol, greases, fat, waxes and oils. Smothering by non-oxygenised agents such as foam, CO2, vaporising liquids such as BCF, or by a fire blanket is effective here. Class C fires involve flammable gases such as propane or natural gas. If possible the gas should be turned off at source (thereby starving the supply of fuel). Carbon dioxide (CO2) or dry powder are recommended for dealing with these fires (though it must be remembered that it is dangerous to remain in the vicinity of gas cylinder fires as they are likely to explode). Class D fires are where the fuel is a metal such as aluminium, sodium, potassium or magnesium. Class F fires involve cooking fats. This category was created fairly recently as effective extinguishing means have been developed. Fire Certificates Since 1971 the fire safety arrangements in places of work such as factories, offices, shops and railway premises have been governed by the Fire Precautions Act 1971. If there are at any one time either more than twenty people at work or more than ten people at work elsewhere than on the ground floor, then the owner or occupier of the premises is required to apply for a Fire Certification issued under the 1971 Act. Fire certificates are also required for hotels and boarding houses if they provide sleeping accommodation for more than six staff or guests. Whether or not a fire certificate is granted will depend to a great extent on: • Who is likely to be using the building • The extent to which materials used or stored in the building are combustible • Ignition sources • Distances of routes to safety; and • The means of controlling or containing fire should it occur. In 1989 two European Council Directives were introduced, the Framework Directive and the Workplace Directive which firmly placed the primary responsibility for ensuring health and safety of the workplace on the employer. These Directives require employers to undertake an assessment of all risks to health and safety at work, including risks from fire. Most of the provisions of these Directives which deal with general fire safety matters were introduced into UK law by the Fire Precautions (Workplace) Regulations 1997 as amended 1999, and are enforced by the Fire Precautions Act 1971. The requirement to carry out fire risk assessments in virtually all workplaces is the key point in these Regulations. © RRC Business Training Section 5 | Management of Common Hazards 5-13 IOSH Managing Safely The Fire Precautions (Workplace) Regulations 1997 as amended 1999, by means of Regulation 3 of the MHSWR, require: "Every employer to make a suitable and sufficient assessment − of the risk to health and safety of his employees to which they are exposed whilst at work, and − the risks to the health and safety of persons not in his employment arising out of or in connection with the conduct of his undertaking," for the purpose of identifying the measures he must take to comply with the requirements and prohibitions imposed upon him. By virtue of Regulation 3, the fire risk assessment may be made as part of the general risk assessment or it may be performed as a separate exercise. Because of the specialised nature of the subject there is much in its favour for carrying out a separate exercise. The Regulations require that 'non-designated' premises which are outside the scope of the Fire Precautions Act 1971 must now be assessed for fire risk. They include hospitals, museums, art galleries, schools, colleges and universities, cinemas, theatres, public houses, clubs, etc. In many instances little will have to be done to comply with the Regulations other than making and recording the fire risk assessment. There are still ‘excepted workplaces’ as defined by the 1999 amendments: • Any workplace which is or is on a construction site • Any workplace which is part of a mine • Any workplace which is or is on an offshore installation, an aircraft, locomotive or rolling stock • Any workplace which is in fields, woods or other land pertaining to agricultural or forestry land • Workplaces used by the self-employed. 5-14 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 3 1. What is likely to happen if you open a window to release the dense smoke in a room created by a fire? (a) (b) (c) 2. Why are sawdust and plastic granules more of a fire hazard than solid timbers or plastic mouldings? (a) (b) (c) 3. Because there are more of them to catch fire Because smaller particles have more surface area exposed to oxygen Because solid timbers are too heavy. What three elements do you need for a fire to start? (a) (b) (c) 4. The smoke will disperse The fire will intensify The fire will go out. Fuel, oxygen and heat Fuel, carbon dioxide and heat Gas, air and dust. What are the three main ways in which fire spreads? (Highlight the appropriate alternatives.) (a) (b) (c) (d) (e) (f) Conduction Substitution Ionisation Convection Radiation Ignition Answers: 1(b); 2(b); 3(a); 4(a), (d), (e). © RRC Business Training Section 5 | Management of Common Hazards 5-15 IOSH Managing Safely FIRE RISK ASSESSMENTS The Fire Precautions (Workplace) Regulations 1997, as amended 1999, require all employers and self employed persons to: • Assess the risk to employees and others who may be affected • Carry out a re-assessment if it appears to be no longer valid, i.e. if there is a change in activity or use of a building which affects the risk • Monitor, review and revise it, as necessary • Record the details of the assessment, if they employ five or more employees • Plan, control and monitor the safety arrangements • Appoint and train an adequate number of people (fire wardens/marshals) to implement an emergency plan. The local Fire Authorities (Fire Services Act 1947) is responsible for enforcing the Regulations. As there are no national standards relating to fire risk assessments, there is no single correct way in which to carry out an assessment. This session covers the main elements to be considered in the assessment, such as: • Who is at risk • The nature of the fire hazards • The level of risk and whether the hazards can be reduced • Control measures that are in place • Whether further control measures are necessary. Carrying out an Assessment In organisations where much of the work is carried out within a single area, it may be adequate to conduct to the assessment of a building as a single unit. However, in most cases it will be necessary to subdivide the building into discrete areas or rooms. It is particularly important not to lose sight of the effects that adjacent work or storage areas or some normally inaccessible areas may have on the rest of the building, e.g. roof voids or boiler rooms; and fuel storage. To overcome this problem it may be useful to first consider the general structure of the organisation and related services, access points and then attach the reports relating to specific work areas to this overview. Identifying Who is at Risk The mobility of people and how familiar they are with the premises will influence the level of risk. If the use of the building is restricted to employees who are physically fit and who are familiar with containment and evacuation, then the risk is likely to be reduced. 5-16 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Determining the Hazards Fire hazards can be subdivided into three main categories: • Combustible materials present • Ignition sources • Structural factors Simple checklists may be used when determining if the combustible material and ignition sources present can be considered as significant. Details of each should be recorded. You should consider the effects of the building or room structure and determine if there are openings around pipes or voids in roof spaces which could aid the spread of fire. Assessing the Level of Risk You can minimise the risk and spread of fire by controlling or maintaining systems which are in place, e.g. regular and routine testing of portable electrical appliances and fixed electrical installations will reduce the likelihood of them being a source of ignition. A 'No smoking' policy will have similar benefits: • Can fire risks be reduced even further? • Should waste be removed more frequently? • Can flammable substances be reduced to those which are in use? • Could the gap around the pipe work running between rooms be filled? Although the primary efforts must be to reduce the likelihood of fire arising, consideration must be given to how a fire should be dealt with if our precautions are ineffective. Obviously the lower the risk of injury the less investment is required to deal with emergencies. Identifying Control Measures Warning Systems For simple low level buildings with a low risk of rapid fire spread there may be no need for automatic detection and warning if the alarm can be raised simply and effectively by word of mouth. However, if the building is in multiple occupancy, with significant numbers of people to evacuate, automatic detection, integrated to a central control and alarm, may be essential. Fire-fighting Equipment In general, the number of extinguishers necessary is determined by the nature of the risk and the size of the floor area. As a rule of thumb consider: • One extinguisher per 200 square metres of floor area • At least one extinguisher per floor • No one should have to travel more than 30 metres to reach an extinguisher © RRC Business Training Section 5 | Management of Common Hazards 5-17 IOSH Managing Safely • Extinguishers should be located near the hazard and/or along a route to safety i.e. not at the opposite end of a room to the door • Extinguishers should be positioned so that the handle is about 1 metre off the floor • Where the floor layout of a building repeats from floor to floor, fire points should be located at similar points on each floor. Escape Routes Irrespective of the level of risk associated with premises the Fire Precautions (Workplace) Regulations 1997, as amended 1999, require that suitable Means of Escape are provided. The general principle that should be adopted is that, other than in very small premises or those presenting low fire risk, there should be alternative means of escape such that, should a fire occur, people present can turn their back on the flames and escape to a place of safety. Where there is more than one escape route, the maximum escape times should be: 1 minute for high risk areas 12 - 25 metres 3 minutes for normal risk areas 18 - 45 metres 5 minutes for low risk areas 45 - 60 metres Remember, this should take into account the time taken to respond to the alarm and to close down equipment. Where people are familiar with the building and with evacuation procedures further distances may be acceptable. A checklist for escape routes would show: • Corridors should be at least 1 metre wide; 1.2 metres is required for wheelchair users • Doorways 750 mm wide will allow 40 people per minute to escape • Doorways 1 metre wide will allow 80 people per minute to escape • Doorways not less than 800 mm wide are required for wheelchair users • Corridor walls should not be decorated with heavy flock wallpaper, carpet material or other combustible materials • Large notice boards should not be located along escape routes. Although a limited number of smaller boards are acceptable they should be regularly maintained to minimise the amount of loose paper • Doors on escape routes should open in the direction of travel if more than 50 people have to pass through, if they are at the bottom of a stairway or if the building is used as a place of assembly such as a conference centre • Escape routes should be kept clear of portable heaters, gas cylinders, electrical appliances such as photocopiers, shredders and microwave cookers, vending and games machines. Furniture should be kept to a minimum. 5-18 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Signs In most workplaces of normal or low fire risk only those escape routes not in common use need be signed. In areas open to public access, all escape routes should be signed. Under the Health and Safety (Safety Signs and Signals) Regulations 1996, all signs showing escape routes should include the running man, open door and arrow pictogram. All safety signs must conform to colour requirements, i.e. rectangular green background with white lettering and white pictogram. Mandatory signs such as 'Fire Action' notices, in prominent positions and 'Fire Door - Keep Shut' are required while additional signs may include notification of site of fire equipment, where this is not obvious. Emergency Lighting Lighting should be provided so that fire exit signs are visible and to illuminate changes in direction or floor level. It is also required in large open plan areas or where it is necessary to close down hazardous processes. The lighting may be provided in the form of 'borrowed light' such as street lamps. Maintaining Facilities and Procedures It is not sufficient to provide facilities and procedures. To be fully effective, a maintenance programme must be in place with details recorded. Such a programme should check physical elements such as extinguishers and escape routes as well as procedural aspects, such as emergency evacuation. Irrespective of the type of activities and buildings involved there are many common day-to-day routine precautions that all companies should be observing and which are outlined below. It is by far the best idea to make one person responsible for checking them on a regular basis. Smoking Unextinguished and carelessly discarded smoking materials are a major cause of fire, especially in waste disposal areas and storerooms: • Where smoking is prohibited (for instance, in a finishing shop), clear 'no smoking' signs should be displayed and the area marked off by a wide red line on the floor • Plenty of ashtrays should be made available where smoking is permitted • 'Illicit' smoking can be discouraged more easily if there are plenty of places where employees may go to smoke • Many companies ban smoking for the last half-hour of the day so that any smouldering materials would be detected. © RRC Business Training Section 5 | Management of Common Hazards 5-19 IOSH Managing Safely Waste Disposal It is not only discarded matches and cigarettes that can cause a fire in waste paper and other scrap materials; sparks from cutting equipment or spontaneous combustion of oily rags, etc., can also start a blaze: • A regular system of floor sweeping and rubbish collection should be implemented in all business premises. Special attention should be given to little-used areas such as behind stairs, around pipes and electrical fittings, etc. • Waste from these regular collections should be emptied daily outside the building in a proper waste disposal area which can be locked off (such as a lockable, closed skip). Routine Checks The worst fires usually break out in areas which have few visitors each day, such as special storage areas. Maintenance checks on all fire fighting and fire prevention equipment, electrical wiring, with special attention given to insulation, is important. Also boundary fences should be checked to prevent the entry of unauthorised personnel. Site Plan A plan of the site with all principal sources of ignition clearly marked is of value to the person charged with the responsibility of fire prevention. The plan should show all electrical appliances, heating plant, site of hazardous processes, location of the electric mains switches and the main gas control valves. It should also show waste disposal areas and the location of fire extinguishers. Inspection The fire hazards plan should be used by the fire prevention staff to make regular inspections against a devised set of checklists. The inspections should be made on a daily, weekly and less frequent but regular basis as outlined in the checklist. 5-20 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 4 1. Identify THREE main points which should be considered when reviewing the provision of fire extinguishers. Highlight the relevant options. (a) (b) (c) (d) 2. Location Size Types Signage (e) (f) (g) Height Access routes Number Select the appropriate definitions in the following statements. A means of escape is: (a) (b) (c) The nearest exit such as a door or window A clear route that can be followed unaided to safety A vehicle that enables a quick get-away. The final exit door should be (d) (e) (f) Kept shut at all times Kept open at all times Fitted with emergency lighting. Escape routes should be posted with signs: (g) (h) (j) 3. Who is responsible for enforcing the fire regulations? Highlight the correct answer. (a) (b) (c) 4. Which clearly indicate the way out Which clearly indicate the fire exits Which clearly show the position of fire hydrants. The HSE The Local Fire Authority The local authority. Fire hazards can be subdivided into three main categories. Select the appropriate ones from the list below. (a) (b) (c) (d) (e) (f) Number of people present on the premises Combustible material Layout of the buildings Accessibility to other buildings Ignition sources Structural factors. Answers: 1: (a), (c), (g); 2: (b), (f), (g), (h); 3: (b); 4: (b), (e), (f). © RRC Business Training Section 5 | Management of Common Hazards 5-21 IOSH Managing Safely EVACUATION PROCEDURES Industrial and commercial premises vary enormously. They may be single storey brick built factories, with no near neighbours but with a permanent workforce and few visitors; shops in a shopping mall with hundreds of customers in and out all day; or offices in a multi-occupied, multiuse block. Any fire prevention policy must take account of the use and occupants of the firm concerned. To reduce injury and damage caused by fire there are three strategies which should form part of fire prevention and control arrangements: • Preventing fire from starting • Preventing fire from spreading • Ensuring everyone can escape safely. Even if all these precautions are observed there always remains plain, ordinary, carelessness which can result in a fire - plus the fact that arson (which now accounts for one third of all UK fires) is becoming an increasingly common crime. This being so, companies must ensure that all staff are aware of, and trained in, the correct procedure to follow in the event of fire. Action in the Event of Fire Instructions should be precise and relate specifically to the particular workplace in question. They will vary according to the size, number of storeys, structural standards, types of process, hazards of the materials used and stored, the number of people employed (with attention being given to who looks after visitors), and means of escape. But there must be a plan and it must be known both through training and practice and written instructions. If anyone is uncertain about what to do, confusion will reign and people could die. The vital elements which must be covered in such instructions are: • Raising the alarm and calling the fire brigade • Tackling the fire • Evacuating the premises. Raising the Alarm Prompt action can often bring a fire under control if it is discovered early. Even if the fire has gained a strong hold, the standard of structural fire protection may be such that it can be contained and extinguished without endangering people in other parts of the building or factory. However, if the fire has reached serious proportions before being discovered, with the danger of its spreading rapidly over a wide area, this must be seen as an emergency situation and immediate evacuation of the entire building will be necessary. In some factories, the processes and materials in use may be such that rapid fire spread is difficult to avoid, so that any fire will demand emergency action. Everyone should know how to report 5-22 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely accurately such essential information as the location of the outbreak, some indication of its extent, and whether the occupants are in danger. In circumstances where there is no immediate danger to life, the person discovering the fire should report quickly to the telephone switchboard or instruct someone else to do so. The internal telephone system will normally be used for this initial notification. There should be some means whereby the switchboard operator can distinguish a fire call from a routine call. If an internal dialling system is installed, this might be achieved by the provision of an emergency instrument in the switchboard room with a distinctive ring. In larger buildings the nearest telephone may be a considerable distance from an outbreak. In such cases the installation of a two-stage manual fire alarm system should be considered; the operation of the first stage should alert the switchboard (or other control centre) and may alert the fire brigade and sound a standby alarm. Evacuation is signalled by the operation of the second stage. When triggered, an automatic fire alarm system will usually put through a pre-recorded telephone request for assistance to the Fire Brigade; but in smaller premises this facility may not be available. The telephone switchboard should have standing instructions on the action to be taken immediately an outbreak of fire is reported. The instructions should cover: • Calling the public fire brigade and on-site fire brigade or fire-fighting unit if available • Notifying senior management and other departments • Notifying any other personnel required either for immediate action or to stand-by. Sounding the fire alarm should automatically mean that everyone evacuates the premises immediately. It should be clearly audible throughout the building and should be readily distinguishable from any other audible signal in use. The signal could take the form of: • Electrically operated sirens, klaxons or bells which can be actuated from the switchboard and from call points throughout the factory • Automatic, electrically operated alarm systems. Such systems should normally incorporate additional points for manual operation • Manually operated sounders such as gongs, triangles or bells. These are suitable for small single and two storey buildings where the fire risk is low. The alarm should be tested regularly at a specific, notified time of day. This should be the only occasion when full evacuation does not take place. Tackling the Fire Many fires can be tackled as soon as they are discovered provided it does not involve personal danger. It is important, however, that anyone tackling a fire should have been properly trained in the use of extinguishers and are aware of the dangers of smoke and fire, especially where this might be towards explosive materials or gas cylinders. Until someone has actually picked up and operated a fire extinguisher onto a real fire they have not been trained. Telling people how to do something is not the same as them doing it. Suitable training depends on the number of people employed in the workplace; the variety of fire © RRC Business Training Section 5 | Management of Common Hazards 5-23 IOSH Managing Safely extinguishers available; the type of fire concerned and the type of risk involved. For expert advice on training, contact the local Fire Brigade's fire prevention officer. There are five types of extinguisher commonly available, which until the beginning of 1997 were coloured as follows: Water Red Foam Cream Carbon dioxide Black Dry powder Blue Inert gas Green Following the introduction of BS EN 3: Portable Fire Extinguishers, all new extinguishers are coloured red, with a zone of colour of up to 5% of the extinguisher body corresponding to the colours above, which indicates the extinguishing agent. So, for example, a new dry powder extinguisher would be coloured red with a blue strip, rather than the old style extinguisher which would have been blue all over. ‘Old’ colour extinguishers may continue in use until the end of their practical lives. Type of extinguisher Class of fire Action/comments Water based extinguishers Class A fires Used to cool burning material. Water is a conductor of electricity and must not be used on live electrical equipment; neither should it be used on flammable liquid fires. Foam Class A and Class B fires The foam forms a blanket over the fire so smothering it. Many foams will conduct electricity so should not be used on live electrical equipment. Carbon Dioxide Class B and C type fires The cooling properties of carbon dioxide are limited. CO2 is suitable for use on fires of electrical origin. Dry Powder Class B and C type fires It is safe to use on electrical equipment but does not readily penetrate spaces inside equipment. Also a general purpose Class A extinguishing agent. Inert Gases (being used to replace halon) Fire Blankets Wet chemical or cloth The advantages of this medium is that it can penetrate small spaces, as in electrical equipment and switchgear, with little resulting damage from the gas. Their use tends to be confined to fixed installations. Class F fires Made in various sizes of glass-fibre material. They are packed in open-ended cylindrical holders or in flat-packed satchels, meant to hang on a convenient wall with the open-end downwards. They have holding-tapes on the edge and the blanket should be calmly but resolutely laid over the top of, for instance, a chip-pan which has caught fire. 5-24 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Fires caused by an electrical fault can result in either a Class A, B or C fire. The power supply should first be disconnected and the fire dealt with according to its classification. Where live electrical equipment is involved and the power supply cannot be switched off, the extinguishing agent should be of the CO2 or dry powder variety. Never use water or foam on live electrical equipment. We will deal with electrical hazards later. Evacuating the Premises Should it become necessary to evacuate the premises, there should be a pre-arranged plan which will enable all employees to leave safely and quickly. It is therefore very important that every employee should be familiar with the escape routes to be used, no matter where they happen to be in the building at the time. They should also be aware of alternative routes should the immediate one be impassable. Everyone should know that a lift must never be used to escape, because a power failure might effectively trap them inside a chimney above a fire. It should be stressed that on hearing the alarm, employees must leave immediately, without panic and without stopping to recover personal belongings and business files, etc. Instructions should be given to all employees as part of their induction stating the route, alternative route(s), and where to assemble for roll call on reaching the open air. This should be reinforced by fire drills (at least once but preferably twice a year). Designated persons should be responsible for checking that everyone has left their particular area or department (including a search of the lavatories, washrooms, etc.). On reaching the assembly point that person (often called a fire warden) should check against a master list to make sure everyone is accounted for (including visitors). Staff Training Responsible Persons Whatever the number of employees, it is vital that responsibility for action in the event of fire is assigned to specific persons. Premises with a large number of occupants may have trained fire wardens who will notify the fire brigade, oversee evacuation and carry out first-aid and fire-fighting. It will also be necessary to nominate a 'senior person', e.g. a safety officer or senior manager, to be responsible for all aspects of fire safety including training, overseeing of fire contracts (e.g. equipment maintenance) and record-keeping. The 'senior person' will organise fire drills and training programmes. Deputies should be nominated to take over these responsibilities when the warden or senior person is absent. Training Staff should be aware of the following information: • How to raise the alarm • What to do on discovering a fire • How to evacuate premises • Where to find fire-fighting equipment and how to use it © RRC Business Training Section 5 | Management of Common Hazards 5-25 IOSH Managing Safely • Where to find escape routes and how to use them. Such training should be given to all new employees; fire certificates frequently specify that induction training should be followed by regular retraining sessions. Fire Drills It is recommended that fire drills take place at least once a year and preferably once every six months. Records should be kept indicating the date, evacuation time, number of participants, etc. Any problems apparent should be analysed and resolved. Staff should not be aware in advance that it is “only” a fire drill, as it may change their response rate. 5-26 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 5 1. Select the correct statements from the following: (a) (b) (c) (d) (e) 2. Alarms should be tested regularly at a pre-notified time of day. On hearing the alarm, all staff must be evacuated, whatever the circumstances. On the outbreak of fire, switchboard should first call the fire brigade. Evacuation is only necessary if the fire has reached dangerous proportions. In no event should staff tackle a fire themselves. Match the definition to the correct extinguishing term: (i) Starvation (ii) Smothering (iii) Cooling 3. Hosing water on the fire Using a fire blanket Taking fuel away from the fire What must staff evacuating a building never do? Select the correct alternatives. (a) (b) (c) (d) 4. (a) (b) (c) Use the lifts Collect their belongings Switch off the computers Close doors and windows. Tick the correct answers to the questions below. (1) (2) (3) How often should fire drills take place? (a) At least once a year (b) Once a month (c) Once a week. Who should take part in fire drills? (a) Only specified people (b) Senior staff (c) All staff. Who should be in charge of fire drills? (a) Nominated fire wardens (b) Departmental managers (c) Safety representatives. Answers: Question 1: (a) and (c) are true. For answer (b) staff need not evacuate a building if the alarms are merely being tested. This is the only time when staff may remain in the building. In answer (e), only trained personnel may tackle a fire and only if it is small. Question 2: (i) (c); (ii) (b); (iii) (a). Question 3: (a) and (b). Question 4: (1) (a); (2) (c); (3) (a). © RRC Business Training Section 5 | Management of Common Hazards 5-27 IOSH Managing Safely ELECTRICITY HAZARDS Electrical appliances are very reliable and electricity is not seen as a major safety hazard. Unfortunately, it is not always appreciated that the normal 240 volts mains supply can be lethal. The consequences of a careless electrical mishap may result in a disastrous fire or horrific injuries. Apart from an electric shock, a victim may receive deeply penetrating burns and permanent disfigurement. The infrequency of electrical accidents is a credit to the introduction of quality wiring systems and sophisticated protective devices. An important safety factor is the speed at which fuses and circuit breakers detect and disconnect a fault. Equipment giving such high speed performance must be well designed, correctly installed and properly maintained. We will now look at the hazards associated with electricity, as well as the workplace precautions and risk control systems which should be adopted. Statutory Requirements Duties on Employers Electrical safety is covered within the broad remit of HSWA. More specifically, the Electricity at Work Regulations 1989 (EAW Regulations) impose detailed safety requirements. The purpose of the EAW Regulations is to reduce the risk of death or personal injury from electricity in work activities. The EAW Regulations impose duties on employers, the self employed and employees, including certain classes of trainees. The Regulations cover all activities involving electrical equipment and apply to electrical systems and equipment used in industry or commerce, whenever manufactured, purchased, installed or taken into use. There is a duty under the HSWA for a manufacturer, importer or supplier of any workplace equipment to ensure that the article is safe when in use. Hand-held or Portable Appliances In the requirements for safety, the EAW Regulations do not differentiate between fixed electrical installations and connected appliances. However, on a day-to-day basis, there is a vast difference in the management of the component parts of an electrical system. For practical purposes a distinction is made between the installation in the building (the fixed part pf the system), which is sometimes called the hard wiring, and the appliances which are connected to it. Appliances are referred to as portable appliances, although the word 'moveable' is sometimes more appropriate. Items such as cookers or photocopiers are hardly portable and the appliance flex may be permanently connected into the mains. For convenience, all of these appliances, and electrical extension leads, with or without plugs and sockets, are referred to as portable appliances. There are no exclusions for particular appliances or locations although some situations (e.g. mines and hospitals) may have additional coverage in other legislation. 5-28 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Principles of Electricity In many ways electricity behaves in a similar fashion to water and many electrical terms and concepts can be related to hydraulic systems (see below): • Electricity is the flow of electrons from atom to atom within a conductor. Current is the flow of electricity and is measured in 'Ampères' (Amps). • Voltage is the force or pressure that causes a flow of current in a conductor and is dependent on the difference in charge at each end of the conductor. Voltage is a potential force and can exist even when there is no flow of current. The unit of electrical force is the 'Volt'. • Resistance to the flow of current within a circuit is influenced by material types and the length of the circuit as well as by the various components fitted in the circuit. Electrical resistance is measured in 'Ohms'. Electricity will only flow if there is an unbroken ring or circuit of conductors from the source of pressure and back again. High Pressure High Voltage (Pressure) Switch Control Valve Electrical Motor Hydraulic Motor Generator Hydraulic Pump Electrical Circuit Low Pressure A Hydraulic and an Electrical System Ohms Law reminds us of the relationship between the basic units and is easily remembered by means of the following equation: Voltage = Current × Resistance Volts = Amps × Ohms Power is the work done in a given time and is expressed in 'Watts'. Electrical power can be determined using the expression: Power = Voltage × Current Watts = Volts × Amps Most electricity used in the workplace is generated and supplied through the mains supply. However, batteries are often used as an additional power source and are not without their own risks. For example a lead/acid battery as might be found in a car or a fork lift truck has specific hazards © RRC Business Training Section 5 | Management of Common Hazards 5-29 IOSH Managing Safely and risks; it contains sulphuric acid which is corrosive and generates flammable hydrogen gas during charging, which can give rise to an explosion risk. Hazards of Electricity Electric Shock An electric shock causes a convulsive response by the nervous system to the passage of electricity through part of the body. No voltage can be considered safe in all circumstances, although low voltages may reduce the risk. We must always assume that the electricity supply of 240 volts is potentially fatal. Shock accidents usually occur when a person makes contact with a live conductor when in simultaneous contact with an earthed object. They also occur, although more infrequently, when contact is made with two live conductors. Once an electric current has passed the barrier of the skin, which has a relatively high resistance, the body itself offers little resistance and the current may take numerous paths through it. The current may have a number of effects on the body including: • Muscular contractions • Respiratory failure • Fibrillation of the heart • Cardiac arrest • Internal burns. Any of these may prove fatal. The severity and type of injury will depend upon: • The magnitude of current passing through the body • The time the current flows • The path taken by the current • If the current is ac, its frequency. (The public electricity supply is alternating current at a frequency of 50 Hz and has the most acute effect on the body.) Susceptibility to electric shock depends upon individual make-up and the environment in which the incident occurs. Wet or damp conditions or those which have a high proportion of earthed metalwork will favour good electrical contact between a live conductor and the body. The effects of a shock current passing through the body from hand-held electrodes is illustrated below: Current (milliamps) Effects 0.5-2 Threshold of perception 2-10 Painful sensation 10-25 Inability to let go, danger of asphyxiation 25-80 Loss of consciousness from heart or respiratory failure Over 80 Burns at point of contact, death from ventricular fibrillation 5-30 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Electrical Burns Burns are caused by the intense heating effect of an electric current as it passes through the body and may result from only a brief passage of electricity. They are likely to be most severe at locations along the path of the current where the resistance is greatest. Burns usually occur on the surface of the skin at points of contact, but high currents can create internal burns which cause damage to red blood cells and muscle tissue. Such deep-seated burns are slow to heal. Burns can also be caused by radiation: from infra-red, which produces a sensation of heat; and from ultra-violet, which can burn the skin and cause 'arc eye' or 'eye flash', which is an eye irritation. The energy of radio frequencies (such as microwaves) can be absorbed by the body and converted into heat which damages deep body tissues. Severe damage can occur before the victim is aware that exposure to the hazard has occurred. Electrical Fires These can be caused in several ways: • Leakage of current due to poor or inadequate electrical insulation, e.g. damaged insulation on flexible cables • Overheating of equipment and cables due to overloading of conductors, e.g. the use of multioutlet adaptors into which a number of appliances are plugged, or flexible cable left wound onto cable drums when current flows • By heating flammable materials placed too close to electrical equipment which is otherwise operating normally, e.g. wastepaper next to electrical equipment which may have hot surfaces while in operation • Ignition of flammable materials by electric equipment which is not operating normally, e.g. arcing or sparking electrical equipment located in or adjacent to flammable vapours or fuel gas • Mechanical damage, e.g. the use of trailing leads or dropped equipment. Prevention of Electrical Accidents Most accidents arising from electrical systems and equipment can be avoided by: • Selecting equipment suitable for the environment Electrical equipment is classified according to the type of environment in which it is expected to work. Ensure that equipment used in adverse environments is designed to operate safely in such conditions. For example, low voltage equipment should be used on building sites. • Installing equipment and protective devices Allow only those who are qualified and competent to carry out work on electrical circuits. Use only reputable companies for installation work. A wide range of protective devices form part of modern installations. These include earthing, double insulation, fuse-protection and circuit breakers as well as means of isolation. © RRC Business Training Section 5 | Management of Common Hazards 5-31 IOSH Managing Safely • Using equipment correctly Ensure that equipment is not abused and that electrical sources are isolated before equipment is opened for running repairs or for un-jamming, e.g. photocopiers. Provide staff training on electrical hazards and safe use of equipment. • Maintaining and testing electrical equipment regularly A programme of regular maintenance, inspection and testing ensures equipment runs efficiently and safely. Introduce daily, weekly and monthly checks for equipment depending upon circumstances, e.g. cables on portable power tools should be checked daily for damage prior to use. Regulation 4 of the EAW indicates that the employer has a duty to maintain all systems so as to prevent danger, so far as is reasonably practicable. The best way to decide when maintenance is necessary to prevent danger is to inspect and test equipment regularly. There is a legal requirement to inspect and test any equipment which may be connected to an electrical supply. Reference is also made to those who can carry out such work and accepts that someone who is competent as opposed to a qualified electrical engineer would be acceptable. To be classified as competent to carry out testing of portable electrical appliances, the following criteria may be considered: • An adequate knowledge and practical experience of electricity and its hazards • A clear understanding of precautions to avoid danger • The ability to recognise at all times whether it is safe for work to continue • The ability to recommend the frequency of testing when required • Adequate understanding of the operating principles of both the test equipment and the unit under test • Adequate knowledge of the required safety standards • Experience in the interpretation of results. Electrical Installations in Buildings Wiring Regulations issued by the Institution of Electrical Engineers (IEE) set standards for the installation and maintenance of the wiring in a building. New installations should be inspected and tested before being put into use. Persons ordering any electrical work should ensure that the contractor issues them with a formal Completion Certificate to confirm that the work is up to standard. The inspection and testing of existing installations in older buildings is also covered in BS 7671 with particular requirements for periodic testing. The IEE Guidance Notes give suggestions for intervals between periodic tests. The actual interval must take into account the circumstances and use of the building. In some cases there are special statutory or local authority licensing requirements. Fire is the most common hazard associated with a badly maintained wiring system. 5-32 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 6 1. Complete the following statement by selecting the appropriate alternatives. The severity of injury due to electricity will depend on: (a) (b) (c) (d) (e) (f) 2. Susceptibility to electric shock The size of current passing through the body The degree of damage to the wires The time the current flows The path taken by the current The location of the injury. Which of the following are TRUE? (Highlight all the statements you think are true.) (a) (b) (c) (d) (e) (f) Electric shock can cause convulsions Electrical adaptors should be used whenever possible Damaged electrical equipment can always be used until the next inspection The only way to get an electric shock is to touch a live surface Flammable materials should not be stored near electrical equipment Only competent people should test and maintain electrical equipment Answers: 1: (b), (d), (e); 2: the following are TRUE: (a), (e), (f). © RRC Business Training Section 5 | Management of Common Hazards 5-33 IOSH Managing Safely MANUAL HANDLING More than a quarter of the accidents reported each year to the enforcing authorities are associated with manual handling. While fatal manual handling accidents are rare, accidents resulting in a major injury such as a fractured arm are more common, accounting for approximately 6% of all major injuries. Most reported manual handling accidents result in over-three-day injuries, frequently a sprain or strain, often in the back. In a bid to reduce the number of accidents the Manual Handling Operations Regulations 1992 (MHOR) were introduced. Common Types of Injury Most reported accidents involve damage to the lower back (strains, sprains and various internal injuries) and are caused by incorrectly lifting or moving a heavy load. They include: • Back injuries, caused by twisting, lifting or pushing loads which are borne on the spine. • Muscular sprains and strains, when a muscle is stretched beyond its normal limit it is strained; a sprain is caused by a sudden or excessive force which weakens a joint and related muscles. • Hernia, which is usually a consequence of incorrect lifting or lifting an excessive load. The musculature of the lower abdomen is strained to the point where a rupture of the body cavity wall takes place, allowing protrusion of part of the intestine. • Cuts, abrasions and bruising; the risk of such injuries can often be reduced by wearing appropriate protective clothing. • Crushing, where fractures, broken or cracked bones are often the result of jamming fingers or dropping objects on feet. The main causes of the injuries we have outlined are: • Failing to use a proper technique of lifting • Moving loads which are too heavy • Failing to grip the load in a safe manner • Not wearing approved protective equipment Assessing the Risks Risk assessments for manual handling operations should: • Be suitable and sufficient • Be carried out by a competent person • Be kept up-to-date and revised when there is a significant change • Be recorded (at least the significant findings) 5-34 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely • Take into account the task, the load, the working environment, individual capability and other factors. The assessment must take account of the following factors: • Requirements of Manual Handling Operations Regulations 1992 (MHOR) • Nature of the handling operations • A basic understanding of human capabilities • Identification of high-risk activities • Practical steps to reduce risk Control Measures The Regulations establish a clear hierarchy of measures: • Avoid hazardous manual handling operations This may be done by redesigning the task so far as is reasonably practicable to avoid moving the load or by automating or mechanising the process. • Make a suitable and sufficient assessment The HSE Guidance Notes on the MHOR can be used to identify those manual handling operations which cannot be avoided and warrant a more detailed examination. The guidelines set out an approximate boundary within which manual handling operations are unlikely to create a risk of injury sufficient to warrant more detailed assessment. This enables assessment work to be concentrated where it is most needed. However, even operations lying within the boundary should be avoided or made less demanding wherever it is reasonably practicable to do so. The guidelines should not be regarded as precise recommendations and should be applied with caution. Where there is doubt, a more detailed assessment should be made. Full height 10kg 5kg 20kg 10kg 25kg 15kg Shoulder height Elbow height Knuckle height 20kg 10kg 10kg 5kg Guidelines based on the assumption that the load is easily grasped with both hands and the operation takes place in reasonable working conditions. If the task involves twisting the body by 45O then the figures should be reduced by about 10%. If the twist is 90O then reduce by 20%. Mid lower leg Load and Stress in Lifting © RRC Business Training Section 5 | Management of Common Hazards 5-35 IOSH Managing Safely • Reduce the risk of injury For manual handling operations which cannot be avoided and involve a risk of injury, the employer must take appropriate steps to reduce the risk of injury to the lowest level reasonably practicable, which in practice requires the development of safe systems of work. Again, the same structured approach as during the assessment of risk is used to consider in turn the task, the load, the working environment and individual capability. Safe Systems of Work A Safe Systems of Work for manual handling operations is essential, complemented by instruction and training of personnel involved. As injuries are most often associated with the task rather than with the particular individuals carrying out the task, improved design of systems should greatly reduce manual handling injuries. Task All tasks involving manual handling operations should be analysed and listed to ensure that no tasks or groups of workers are overlooked. The type, frequency and duration of movements should be analysed with the intention of identifying those movements most likely to cause injury. Consider if the task can be modified to minimise risk. The main aim should be to try to avoid the task if possible. Load A load may constitute a hazard because of its weight, size, shape, resistance to movement, rigidity or lack of it, position of the centre of gravity, presence or absence of handles, or surface texture. Therefore, assessments which concentrate exclusively on weight limits are insufficient, although weight is a vital consideration. Although there is no 'safe' weight, it has been proved that the incidence of back injury increases with the weight of the load. Certain loads require particular attention as they require special handling techniques, as in the case of barrels, drums, kegs, sacks, sheet material, long loads, cylinders, coils or reels. For example, a sack can be potentially hazardous not only due to its weight but also because of its shape, lack of rigidity, lack of corners to hold; it may be slippery when wet and liable to split open with rough handling. Unfamiliar loads require particular assessment as experience of the nature of the load will be limited. The risks associated with unfamiliar loads can be reduced if the approximate weight and centre of gravity are clearly marked, preferably on all sides of the load. Contents should be securely packed so the load is balanced and the centre of gravity static. If this is not possible, it should be clearly indicated. Other methods of reducing risks, apart from providing mechanical aids, include training in manual handling techniques, use of two-man lifts, provision of hand grips or handles on loads. Consider if the load can be broken down into smaller units or if the goods could be delivered and moved in bulk. 5-36 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Environment An assessment of the environment in which manual handling operations take place should include the routes taken by loads, in order to identify unnecessary, dangerous and/or lengthy journeys. Routes should be designed to minimise manual handling by utilising the optimum pathways, i.e. those which minimise the amount of manual effort, twisting, bending, stretching, carrying distance and discomfort. Where practicable, pedestrian and vehicle routes should be separate; storage areas should be designed so that storage heights minimise the need to over-reach and bend down; and workstation levels should be variable to allow for individual stature and the types of tasks undertaken. We must also take into account slipping and tripping hazards, poor lighting, high raise levels, and poor weather problems. Individual Capability In general, if a task requires fit strong people to carry it out, then it should be redesigned. Each person has individual capabilities and limitations which must be considered when assessing manual handling operations. People's health, strength and fitness as well as their training, skill and experience affect their ability to do a job safely. Before employing a person in a manual handling job, a pre-employment medical should be carried out to establish the person's general fitness, or warranty a relevant previous injury or complaint. An individual's general health and fitness should be monitored regularly and appropriate steps taken if there are changes. If a person's health does change, it may be necessary to alter the system of work to suit the new circumstances or move the person to other, more appropriate tasks. Those who are overweight, underweight, arthritic, with painful backs or joints, chest or heart complaints, or suffering from a rupture or prolapse may be unsuited to some types of manual handling. Training Developing a Safe System of Work There are five essential stages involved in the development of a safe system of work: • Assessment of the four factors outlined above, i.e. task, load, environment, individual capability • Hazard identification, e.g. excessive bending, awkward load, unsuitable floor area, employee with high blood pressure • Development of safe methods, e.g. redesign task to exclude excessive bending by increasing height of work surfaces, use mechanical handling aids or two-person lifts, repair damaged or unsuitable flooring to eliminate tripping hazards, redesign task to suit the individual or find a more suitable alternative task • Implement the system, including employee training, information and instruction • Monitor the system to ensure its correct use and continued effectiveness by using supervision, random and routine checks and formal audits. © RRC Business Training Section 5 | Management of Common Hazards 5-37 IOSH Managing Safely Instruction If all the factors we have discussed have been optimised, safe manual handling operations can be enhanced by instruction in safe systems of work and training in handling techniques and/or mechanical aids. However, note that while training in handling techniques may be appropriate and beneficial, it should not be a substitute for the development of a well-designed safe system of work. Instruction and training should be closely related to a person's work and include theoretical and practical supervised sessions using typical loads in working conditions. Statutory Requirements The Manual Handling Operations Regulations 1992 (MHOR) were made under the Health and Safety at Work etc Act 1974 and were introduced to comply with European Directive 90/269/EEC. An important general point about the Regulations is that they are intended to prevent injury to any part of the body, not just the back. The MHOR do tend to focus on factors which increase the risk of back injury; however, they are not restricted to lifting operations but cover every activity involving pushing, pulling, lifting, or holding. Indeed wherever a load is transported or supported manually the Regulations apply, including such operations as sliding open large doors or moving furniture. The Regulations follow a similar format to most other safety legislation introduced at that time, in that a general assessment of workplace risks to the health and safety of employees must be undertaken. There is now general acceptance of both the scale of the manual handling problem and the importance of preventive methods. Modern medical and scientific knowledge stresses an ergonomic approach in removing or reducing the risk of manual handling injury. Ergonomics is sometimes described as 'fitting the job to the person, rather than the person to the job'. The ergonomic approach therefore looks at manual handling as a whole, taking into account a range of relevant factors including the nature of the task, the load, the working environment and individual capability. This approach is central to the European Directive on manual handling and to the Regulations. The Regulations should not be considered in isolation. As we have seen, Regulation 3(1) of the Management of Health and Safety at Work Regulations 1999 (MHSWR) requires employers to make a suitable and sufficient assessment of the risks to the health and safety of their employees while at work. Where this general assessment indicates the possibility of risks to employees from the manual handling of loads then a comprehensive assessment must be undertaken. 5-38 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Activity 7 1. Which of the following can give rise to manual handling injuries? (Tick those you think are appropriate.) (a) (b) (c) (d) (e) (f) (g) 2. Working at heights Working in confined spaces Poor lifting technique Moving loads which are too heavy Pushing or pulling loads Failing to hold the load in a safe manner Not wearing approved protective equipment. The Manual Handling Operations Regulations 1992 place certain obligations on employers. Tick all the correct answers. (a) (b) (c) (d) (e) (f) To carry out risk assessments of manual handling operations To employ people who can do the job To provide personal protective equipment To apply an ergonomic approach to manual handling To provide details of weight and nature of the loads to be handled To provide appropriate mechanical aids. Answers: 1. You should have ticked (c), (d), (f), (g); 2. You should have selected (a), (d), (f). © RRC Business Training Section 5 | Management of Common Hazards 5-39 IOSH Managing Safely MECHANICAL HANDLING Introducing external powered machines to help with handling procedures may be more effective than manual handling but it also increases the chances of more severe accidents. There are four factors that should be considered when looking at mechanical hazards: • The workplace must be designed in such a way as to minimise contact between people and the load as it is being moved • The load itself should be packed for storage and transport in a manner that minimises the risk of handling accidents • The handling equipment should be in good condition, well maintained and designed for the job • Finally, all operators should be trained and competent to use the equipment. Lifting Equipment Equipment used for the lifting of goods only or goods and people is subject to additional legislation in the form of the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). These Regulations apply to all forms of equipment and accessories, from tower cranes through office lifts to patient hoists and slings, and requires comprehensive inspection and test programmes to be in place. Equipment that is used to lift people is required to be tested every six months, while those lifting goods only usually require formal inspection and testing at 12 month periods. Where you are involved with such equipment it is important to refer to these Regulations. Mobile Work-equipment Employees may only be carried on equipment that has provision to allow their safe transport. Wherever possible this should be in the form of a seat, although there are exceptions allowed where work necessitates. This does not condone staff riding on the forks or pallets of a fork-lift truck. Working platforms must be fitted with guard rails. In all instances, employees/passengers must not be able to come in contact with moving parts, be they wheels, tracks or other components. Where there is a risk of injury from being thrown from the equipment then suitable body restraints must be fitted. This could be in the form of a full body harness or a lap restraint. Where there is a risk of equipment rolling over then efforts must be made to improve stability and to reduce the risk of injury by limiting how far over the equipment can roll. Effectively, this Regulation requires the fitting of roll-over protective structures (ROPS) to all mobile equipment liable to roll. 5-40 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Again, where there is a risk of injury from being crushed by the equipment, then suitable body restraints must be fitted. As vertical-masted fork-lift trucks will normally prevent a roll-over of more than 90 degrees, some of these trucks may not require ROPS. Seat restraints would however be used as well as protection against falling objects. (Falling object protective structures are abbreviated to FOPS.) Self-propelled Work-equipment Equipment such as dumper trucks, excavators, tractors, ride-on floor polishers, etc., must be fitted with devices to prevent them being started by unauthorised persons. They must also be fitted with a service and secondary braking system as well as means of improving the driver's visibility where this is restricted, e.g. mirrors. If the equipment is to be used at night or in dark places, lights must be fitted. Activity 8 When using handling equipment, what aspects would you have to consider? Tick the alternatives you think apply. (a) (b) (c) (d) (e) (f) (g) (h) (i) (j) Do the operators have a driving licence? Are the operators trained and competent? Are operators wearing protective clothing? Is the route clear of obstruction? Are the materials to be handled securely packed and fastened? Are the contents of the load breakable? Does the equipment have lights? Does the equipment have specific design or load limits? Is there a horn? Is equipment in good working order? Answers: (b), (d), (e), (h). © RRC Business Training Section 5 | Management of Common Hazards 5-41 IOSH Managing Safely HAZARDOUS CHEMICALS All chemicals can harm your health if used or handled in sufficient quantities or in inappropriate ways. When we consider chemicals in the workplace, we are concerned with substances and preparations, which are used directly in work, such as paints or cleaning materials. We are also concerned with chemicals which arise from the work, such as the dusts or fumes given off during a process, maybe grinding or heating solid metals. Chemical substances and preparations exist in a variety of physical states which affect the way in which chemical hazards arise in the workplace: • Liquids • Gases • Vapours • Mists • Fumes • Dusts Classification of Hazardous Substances Because different substances may be hazardous in different ways, specific phrases are used to differentiate between the degrees of hazard: • Very toxic Very toxic substances and preparations are those which in very small quantities cause death or acute or chronic damage to health when inhaled, swallowed or absorbed via the skin. • Toxic Toxic substances and preparations are those which in small quantities cause death or acute or chronic damage to health when inhaled, swallowed or absorbed via the skin. • Harmful Harmful substances and preparations are those which may cause death or acute or chronic damage to health when inhaled, swallowed or absorbed through the skin. • Corrosive Corrosive substances and preparations are those which may on contact destroy living tissues, e.g. sulphuric acid. • Irritant Irritants are non-corrosive substances and preparations which through immediate, prolonged or repeated contact with the skin or mucous membrane may cause inflammation. • Sensitising Sensitisers are substances and preparations which may cause an allergic reaction. 5-42 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely • Carcinogenic Carcinogenic substances and preparations are those which if inhaled, ingested or absorbed by the skin may induce cancer or increase its incidence. • Mutagenic Mutagens are substances and preparations which alter cell development and cause changes in future generations. • Toxic for reproduction These are substances which may affect male or female fertility or harm a foetus, such as teratogens which cause abnormal development of an embryo, resulting in stillbirth or birth defects. Acute and Chronic Health Effects Acute health effects arise where the quantity of a toxic or harmful substance absorbed into the body produces harmful effects very quickly, i.e. within seconds, minutes or hours. Alcohol has an acute effect; drunkenness is caused by the effect of alcohol on the central nervous system. The term chronic toxicity describes a condition where the harmful effects of a substance absorbed into the body take a very long time to appear, possibly months or perhaps years. The conditions produced by the toxin usually result from absorption of small quantities over a period of time. Alcohol has a chronic ill-health effect in the form of liver damage. Human Senses Hazardous substances can sometimes be detected by human senses, which is helpful because people can actually tell that the substance is present. However, many substances cannot be detected by unaided senses, which means people will be unable to tell that the substance is present in the workplace. For example, carbon monoxide (CO) is a colourless, odourless, tasteless gas. It is found in combustion gases such as coal gas, car exhaust, producer gas, blast-furnace gas and water gas. CO is toxic. Concentrations above 5% cause immediate loss of consciousness, but far more people are killed by exposure to much lower concentrations over a period, typically when a gas-fired heater is used in a poorly ventilated room. Routes of Entry Substances can enter the body in many different ways: © RRC Business Training Section 5 | Management of Common Hazards 5-43 IOSH Managing Safely Routes of Entry • Inhalation Entry is through the nose or mouth and along the respiratory passages to the lungs • Ingestion Entry is by the mouth and may occur as a result of swallowing the agent directly, from eating/drinking contaminated foods, or from eating with contaminated fingers • Absorption Entry is through the skin or via the eyes • Injection Entry is direct into the body by high pressure jet or contaminated sharp objects piercing the skin. Note that the route of entry into the body is critical in determining the appropriate control measures. Thus, where there is a risk of direct absorption, workers should be protected with appropriate protective clothing to prevent contact between the agent and the skin, or where the key entry route is through inhalation, respiratory protection must be provided. Sources of Information There are several good sources of information which can be used when trying to determine how hazardous a particular chemical is and how it should be used in the workplace: 5-44 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely • Product Labels OLD BILL’S CITRIC THICK BLEACH contains Sodium Hypochlorite and Sodium Hydroxide Keep out of reach of children. Irritating to eyes and skin. Avoid contact with skin and eyes. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water. If swallowed, seek medical advice immediately and show the container or label. Prepared by G and F Cleaners Ltd 431 Ocean Drive, Blackpool BL47 2FN, UK Tel: 018050 999111 • HSE Guidance Note EH40 Guidance Note EH40 is the prime source of information about airborne contaminants. It contains the lists of occupational exposure limits for use with the COSHH Regulations and is updated annually. • Manufacturers' Safety Data Sheets These are intended to provide users with sufficient information on the hazards of the chemicals for them to take appropriate steps to ensure health and safety in the workplace in relation to all aspects of the substance’s use, including its transport and disposal. Safety data sheets must be supplied free of charge when the substance is first provided. They must be kept up-to-date and revised and reissued accordingly. Control Measures The precautions taken to control risks arising from chemical hazards should be established following an appropriate risk assessment. Some general precautions must always be in place, in particular first-aid measures must be in place to deal with accidental exposure. Both the Management of Health and Safety at Work Regulations and the Control of Substances Hazardous to Health Regulations require that measures conform to a general hierarchy of control: • Elimination The first priority for control of any significant risk to health is to try to eliminate completely the agent responsible in the first place. The option often exists to eliminate the hazard at source by © RRC Business Training Section 5 | Management of Common Hazards 5-45 IOSH Managing Safely replacement with another substance or process which does the same job, but presents no risk to health. • Substitution Although elimination of risk is the ideal, it is often not practicable. The next option then becomes reducing the risk by substituting the hazard with a different one with less potential for harm. • Process Changes In some circumstances an analysis of the process itself may identify specific activities which produce harmful substances or agents. In such cases, changing the work method may minimise or suppress the generation of the agents of concern. For example, brush painting rather than spraying will considerably reduce the level of airborne contaminant. • Reduced Time Exposure The ill-health effects arising from hazardous substances and agents in the workplace are often related to the length of time of exposure as well as the severity (the concentration of the contaminant) of the hazard. As a consequence, reduction of exposure can be used as a means of minimising possible ill-health effects. • Enclosure and Segregation Total enclosure or containment of the hazard is the best form of control since no one can then be exposed to it. Where isolation of the source is difficult, it may be more practical to enclose the workers to ensure they remain segregated from the hazard. • Local Exhaust Ventilation Local exhaust ventilation (LEV) is the standard control measure for dealing with dusts, vapours and fumes which are generated from a point source. The harmful contaminant is extracted at the point of generation using engineered systems to ensure that the direction of the ventilation flow is away from the breathing zone of any operators. • Dilution Ventilation Dilution ventilation operates by simply diluting the contaminant concentration in the general atmosphere to an acceptable level. This is achieved by efficiently changing the air in the workplace over a given period of time; for example, a number of complete changes every hour. The workplace air will be extracted by the use of fans set in the walls or roof, with fresh air being pumped in. • Personal Protective Equipment There are situations where personal protection is the only, or the most appropriate, method to deal with a particular hazard; for example, when the cost of controlling the hazard at source is high and the time required for protection is short. As a generalisation, the need for personal protection during normal working should be avoided. However, there will always be some exceptions to this rule and protective footwear, headgear, hand protection and special clothing are worn during most, if not all, of the working time in some cases. 5-46 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely DISPLAY SCREEN EQUIPMENT Display screen equipment (DSE) covers all equipment used in the workplace to display information with which the user interacts in some way, usually by inputting or out-putting information by use of a keyboard or other device, as part of his/her work. Thus it covers computers and their associated control devices as well as certain other types of equipment, such as microfiche or radar (air traffic control) terminals. It specifically excludes displays and instrumentation in drivers’ cabs or machinery which is there purely to supply information. Users of DSE are those for whom working with the equipment forms a major part of their work. Because the risks associated with the use of DSE are mainly related to prolonged use, those who only occasionally make use of such equipment are excluded. Users will be those who utilise the equipment on a regular basis for periods of over one hour at a time. Workstations comprise the totality of equipment used at a fixed point by an individual user, including any display screen equipment, tables and chairs, storage facilities and other equipment used as part of the work. Ill-Health Effects DSE Workstations Musculo-Skeletal Disorders These are injuries and disorders of the muscles, nerves, tendons, ligaments and joints, cartilage and spinal column. Typical problems include: • Work-related upper limb disorders (WRULDs) such as Tendonitis, which is a swelling or irritation of a tendon which induces pain, tenderness, and occasionally restricted movement of the muscle attached to the affected tendon. These conditions used to be called Repetitive Strain Injuries (RSI). • Back disorders, including slipped discs and strains in the lumbar, sacro-iliac or the pelvic region at the base of the spine. Eye Problems Visual fatigue (or eye strain) is brought about by the eyes having to work at the limit of their capabilities for long periods. Symptoms include irritation of the eyes (inflammation, itchiness), breakdown of vision (blurred or double vision) and referred symptoms (headaches, giddiness, fatigue). Strain injuries such as neck and backache can also occur as the person bends to get closer to the screen being viewed. Facial Dermatitis A small number of complaints related to the supposed effect of VDUs on facial skin, ranging from occasional itching and prickling of the skin to reddening and more substantial rashes. Photosensitive Epilepsy VDUs do not cause epilepsy, but it is possible that they could trigger a photosensitive response amongst individuals who already suffer from certain kinds of epilepsy. However it is a very rare © RRC Business Training Section 5 | Management of Common Hazards 5-47 IOSH Managing Safely occurrence which has only been noted in respect of the rapid screen movement and lighting effects associated with certain computer games. Radiation Effects Concern has been expressed over electro-magnetic radiation emitted from VDUs. However, extensive studies by various bodies throughout the world have concluded that emission levels are well below national and international limits for occupational exposure. Effects on Pregnant Women There has been some concern that higher levels of miscarriage and birth defects have been experienced among VDU users. However, reliable studies have been unable to demonstrate any link, and it has been suggested that the problem may be caused by worry and anxiety rather than through actual VDU use. Women who are pregnant or planning children and are worried about working with VDUs are advised to talk to their doctors. Analysis of a DSE Workstation Environment and Equipment The key areas for consideration are shown in the following diagram (reproduced from Display Screen Equipment Work, Health and Safety (Display Screen Equipment) Regulations 1992, Guidance on Regulations, L26): Workstation Ergonomic Factors The numbered subjects in the diagram are dealt with below: 1. General lighting and heating: The general level of lighting in the area must be adequate for the tasks, with no excessive contrast or shadows in the immediate work area, and the heating maintained at a comfortable level with no draughts. 5-48 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely 2. Local lighting: Additional lighting may be necessary to provide sufficient illumination of the immediate work area to suit the needs of the task, with no glare or distracting reflections. 3. Distracting noise should be minimised: Illustrated in the diagram by a shielded printer. 4. Sufficient leg-room and clearance should be provided to allow for changes of posture and other general movement to suit the individual, and without being cramped. 5. Windows should allow plenty of natural light wherever possible, but coverings must be provided to prevent glare and excessive heat. 6. Software or information displayed on the screen must be appropriate for the task and be capable of adaptation to the needs of the user (for example, by allowing adjustment of the size of the work area displayed), provide feedback on the systems status and there should be no undisclosed monitoring. 7. The screen itself should provide a stable image, be of sufficient size to allow the information to be read easily and be free of glare or reflections. The screen should also be adjustable (see below). 8. The keyboard should be of appropriate design to be usable with comfort, with the keys being of sufficient size and clarity to suit the demands of the task. Again, it should be fully adjustable to suit the needs of the user. 9. Work surface: This should be large enough to accommodate all necessary equipment and other items used from time to time, and allow them to be arranged to suit the individual’s needs. 10. Work chair: This should be fully adjustable to suit the needs of the user. 11. Footrest: Should be provided to assist posture if required. Interaction Between the User and the Equipment The key consideration here is that, wherever possible, equipment should be adjustable to suit the needs of the individual user and where, of necessity, equipment is in a fixed position, it should be positioned so that the user is able to reach and use it with comfort: • Workstations, including seating and access, should be suitable for any special needs of the individual worker, including workers with disabilities • The worker should be at a suitable height in relation to the work surface • Work materials and frequently used equipment or controls should be within easy reach, without undue bending or stretching • There should be sufficient clear and unobstructed space at each workstation to enable the work to be done safely, allowing for the manoeuvring and positioning of materials. This should also provide for adequate freedom of movement and the ability to stand upright. Unavoidable spells of work which have to be carried out in cramped conditions should be kept as short as possible and there should be sufficient space nearby to relieve discomfort. Thus, in relation to the workstation shown in the diagram, the telephone should be capable of being moved to the preferred position of the user (left or right hand side of the desk, and not requiring a © RRC Business Training Section 5 | Management of Common Hazards 5-49 IOSH Managing Safely stretch to reach it) and the drawers should be at a comfortable height and position to provide easy access and sufficient immediate storage. The chair should be easily movable to allow for adjustment of position and access. The document holder can also be positioned at a height and location to minimise head and neck movement. The diagram below, also from the Guidance Notes to the Health and Safety (Display Screen Equipment) Regulations 1992, as amended 2002, highlights the need to consider posture in the arrangement of equipment. Seating and Posture for Typical Office Tasks The numbered subjects in the diagram are: 1. Seat back adjustability 2. Good lumbar support 3. Seat height adjustability 4. No excess pressure on underside of thighs and backs of knees 5. Foot support if needed 6. Space for postural change, no obstacles under desk 7. Forearms approximately horizontal 8. Minimal extension, flexion or deviation of wrists 9. Screen height and angle should allow comfortable head position 10. Space in front of keyboard to support hands/wrists during pauses in keying. Additional specific guidance on the positioning of equipment and posture includes the following: • For tasks consisting of prolonged and consistent use of a display screen (such as data entry), the keyboard height should be such that when the user’s fingers are resting comfortably on the home-row keys, the angle of the elbow should be 90 degrees 5-50 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely • The keyboard should be able to be tilted and separated from the screen, so the operator can find a comfortable position, thereby avoiding fatigue in the arms or hands. A wrist rest can reduce stress on the lower arm both when typing or if work relies on much use of the mouse • For displays with tilted screens, the imaginary line joining the centre of the screen to the user’s eye should be about 15 degrees below the horizontal, in the operating position • The VDU should ideally be viewed from a distance of about 350 to 600 mm. The desk or table should be deep enough to accommodate the display unit for viewing at these distances without cramping the work surface in front of it. The top of the screen should be approximately at eye height. Additional Precautionary Measures Breaks from Screen Use Provision should be made for frequent short breaks, as they appear to be more satisfactory than longer ones taken occasionally; they should be arranged so that they are taken prior to the onset of fatigue and not as a recuperative period from it. Information and Training Of prime importance is the provision of information and training; in correct posture, including the adjustment of work equipment to suit the individual, and in the correct use of that equipment, including the software used on a computer. Eye Sight Tests Eyesight tests should be carried out routinely to identify any eyesight problems, and to provide effective and remedial action; for example, providing spectacles. The test, as well as the provision of spectacles if not normally required, must be at the cost of the employer. © RRC Business Training Section 5 | Management of Common Hazards 5-51 IOSH Managing Safely NOISE AT WORK We are surrounded by sound all the time; we use it as a means of communication and as a source of entertainment (music). However, in certain circumstances, it can be an intense irritation and a considerable hazard at work. In such circumstances, unwanted sound is usually referred to as noise. The major problem of noise is hearing damage, but it can also cause disturbance which can impair efficiency, interfere with communication, and thus increase the risk of accidents and stress. The Noise at Work Regulations 1989 provide the framework for addressing these problems, although they are almost exclusively concerned with the risk of damage to hearing. Effect on Hearing of Exposure to Noise In moderation, noise is harmless, but if it is too loud it can permanently damage hearing. The danger depends on how loud the noise is and how long people are exposed to it. The effects may be acute or chronic: • Acute effects are where the peak pressure of the sound wave may be so great that there is a risk of instantaneous damage to the mechanism of the ear. This is most likely when explosive sources are involved, such as cartridge-operated tools or guns • Chronic effects are where constant exposure to excessive noise over a period of time gradually produces damage to hearing. This form of damage may not be noticed until it has become permanent. Generally, permanent damage to hearing is irreversible. Surgery may reduce the damage in the case of acute injury to the eardrum, but there is no cure for hearing impairment. The effects of damage to the hearing mechanisms of the ear may take several forms: • Sounds become muffled so that it is hard to tell similar sounding words apart, or to pick out a voice in a crowd, and it is difficult to distinguish speech from background noise. This effect is known as “threshold shift”, indicating that the level at which sounds can be clearly distinguished has reduced. The condition may be permanent or temporary • Noise-induced hearing loss occurs where the ear is unable to respond fully to sound within the speech range. The person does not necessarily lose the ability to hear sound, but is unable to distinguish the spoken word clearly even if it is presented with a raised voice • Tinnitus is a subjective condition where “noises in the head” or “ringing in the ear” are the descriptive symptoms. There are no observable external symptoms. It may be an acute condition which recedes with time, although the recovery period could be twelve or more hours where very high exposure levels occur. It may also occur with people who have a chronic noise-induced hearing impairment, in which case it is usually permanent. Where conditions in the workplace are such that it is necessary to shout in order to be understood, or there is a difficulty being understood by someone about two metres away, there is likely to be a problem and the noise level will have to be assessed by a competent person. 5-52 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely Noise Assessment and Action Levels The damaging effects of noise are related to the total amount of energy or “dose” which the ear receives. The dose/energy depends on two factors: the level of noise, which is measured in a weighted decibel scale (dB(A); and duration of exposure. It is commonly accepted that equal amounts of noise energy entering the ear cause the same effect to exposed workers irrespective of the noise or exposure profiles. Thus a short exposure to a high level of noise is considered to cause comparable hearing damage to a long exposure to a low level of noise. This is illustrated in the following table by reference to an exposure equivalent to 90 dB(A) for eight hours (a working day): Sound Level in dB(A) Exposure Equivalent 90 8 hours 93 4 hours 96 2 hours 99 1 hour 102 30 mins 105 15 mins 108 7.5 mins Each exposure represents 100% of permitted exposure equivalent to 90 dB(A). Note that if the sound level is doubled (represented by a 3 dB(A) increase) then the duration of exposure has to be halved for the total dose to remain the same. The concept of the noise “dose” to which a person may be exposed over the course of a working day (eight hours), and its equivalents for shorter periods of time, lies behind the specification of “action levels” in the Noise at Work Regulations. These are exposure levels at which the employer is required to take particular steps to protect employees and others from the harmful effects of noise. The action levels are set at values of daily personal exposure to noise. These depend on the noise level in the working areas and how long people spend in them during the day. There are two action levels: the first is set at 85 dB(A) and the second at 90 dB(A). Thus, we can see from the table above that, for the second action level to become operative, a worker would have to be exposed to a level of 90 dB(A) for eight hours, or to a level of 102 dB(A) for only 30 minutes. Where the daily personal exposure is below 85 dB(A) the employer has a responsibility to reduce the risk of hearing damage to the lowest level reasonably practicable. Where it is above that, action is specified as follows: • First Action Level Where the daily personal exposure is above 85 dB(A) but below 90 dB(A), the employer should ensure that: − Noise assessments are carried out or noise levels identified © RRC Business Training Section 5 | Management of Common Hazards 5-53 IOSH Managing Safely − Employees are informed about the risks to hearing and what they should do to minimise those risks, including the use of PPE − Ear protectors are freely available, should they be requested, and are properly maintained. Note that it is not a legal duty for the workers to wear protection below the second action level, but there is a duty on employers for equipment to be available if employees ask for it. • Second Action Level Where the daily personal exposure is above 90 dB(A), the employer should ensure that: − Noise assessments are carried out or noise levels identified − Exposure to noise is reduced as far as is reasonably practicable by means other than ear defenders − Employees are informed about the risks to hearing and what they should do to minimise those risks − Ear protection zones are marked (i.e. with safety signs) if reasonably practicable − Employees (and others entering the marked zone) are provided with ear defenders and compelled to wear them. Basic Noise Control Techniques Wherever noise is a problem there are three orders of priority for dealing with it: • Noise reduction at source: By elimination or substitution of the process or equipment producing the noise; for example, diesel/petrol engines replaced by electric motors • Attenuation in transmission: By engineering controls which limit the amount of noise transmitted; for example, the simple expedient of isolating the machine on anti-vibration dampers or rubber mountings may reduce noise levels considerably • Personal protection: The use of ear protection, only if neither of the first two approaches results in a satisfactory solution. Personal Hearing Protection Where people have to work in noise-hazardous areas, i.e. above 85 dB(A), ear protectors (ear muffs or ear plugs) must be made available. However, they should not be regarded as a substitute for noise reduction. The employer is still required to reduce the noise exposure by other means, as far as this is reasonably practicable. Hearing protection should be chosen to reduce the sound level at the user’s ear to below the limit for unprotected exposure. It must be worn all the time to give the protection it is designed to achieve and should not be removed, since even a short exposure in a high noise environment represents a significant noise dose: 5-54 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely • Ear muffs or ear defenders These are normally hard plastic cups which fit over and surround the ears, fitted to the head by cushion seals filled with a soft plastic foam or a viscous liquid. A simple padded band over the head holds the cups comfortably in position and allows the muffs to be slipped off easily when not required. However, this prevents use of a hat or helmet. • Ear plugs These are small pieces of acoustic absorbing material which are inserted directly into the ear. They can be supplied with a cord or a neck band to prevent loss, useful in the food industry for example. Hearing protection must be selected with care, because different ear defenders or plugs will have different “attenuation characteristics”. In other words, they will reduce sound level by varying amounts at different frequencies. If the noise problem is all at high frequencies (high pitch), then a set of ear defenders which offer protection only at low frequencies (low pitch) will be ineffective. © RRC Business Training Section 5 | Management of Common Hazards 5-55 IOSH Managing Safely SUMMARY • There is a legal obligation upon employers to carry out safety inspections at regular intervals to identify faults which could result in injury. Safe Systems of Work and Permits-to-Work arrangements should be adopted for high-risk maintenance and repair work. Particular care must be taken for staff working at height or in confined spaces. Emergency and rescue arrangements should be put in place before staff can be allowed to enter confined spaces. Efforts must be made to segregate pedestrians and traffic. • For fire or combustion to occur, three essential elements have to be present: − Fuel − Oxygen − Heat/ignition source. Remove any one of these elements and the fire cannot burn. These three components are frequently referred to as the Fire Triangle. The main hazards associated with fire are: − Toxic fumes produced by combustion − Smoke causing suffocation and loss of visibility − Burning by heat or flames − Suffocation due to depletion of oxygen within the atmosphere − Collapse of building or structure due to failure of materials Heat always travels from regions of high temperature to regions of lower temperature. Heat is transmitted in three different ways: • − Conduction − Convection − Radiation. Fire risk assessments are required under the Fire Precautions (Workplace) Regulations 1997, as amended. Fire risk assessment should include details of : − Who is at risk − The fire hazards − The level of risk − Whether the hazards can be reduced − Control measures that are in place − Whether further control measures are necessary 5-56 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely The risk of fire can be reduced by: − Maintenance of critical equipment − Waste disposal and good house keeping − Smoking policy − Security. The risk from fire can be reduced by: • − Early detection methods − Prompt notification of all staff, visitors and emergency services − Orderly evacuation of staff and visitors − Containment by using appropriate building construction and extinguishers − Staff induction and training, and information relating to evacuation practices and signage. In most situations, fires can be divided into three general types, each one being grouped according to the form of the combustible material or fuel: Class Fuelled by Control Class A Freely burning fires in wood, paper, textiles or any other ordinary combustible material Cooling with water is the most effective medium for extinguishing this type of fire. Class B Flammable liquids such as alcohol, greases, fats and oils Smothering by non-oxygenised agents such as foam, CO2 or by a fire blanket. Class C Flammable gases such as propane or natural gas If possible the gas should be turned off at source (thereby starving the supply of fuel). CO2 or dry powder are the recommended extinguishing agents for dealing with these fires (though it must be remembered that it is dangerous to remain in the vicinity of gas cylinder fires - they are likely to explode.) • Electricity is the flow of electrons from atom to atom within a conductor. − Current is the flow of electricity and is measured in Amperes (Amps). − Voltage is the force or pressure that causes a flow of current in a conductor. Voltage is a potential force and can exist even when there is no flow of current. The unit of electrical force is the Volt. − Resistance to the flow of current within a circuit is influenced by material types and the length of the circuit as well as by the various components fitted in the circuit. Electrical resistance is measured in Ohms. − Power is the work done and is measured in Watts. © RRC Business Training Section 5 | Management of Common Hazards 5-57 IOSH Managing Safely Fires of electrical origin can be caused in several ways: − Damaged insulation on flexible cables − Overheating of cables due to overloading − Overheating of adjacent flammable materials − Ignition of flammable materials from an electrical spark An electrical current passing through a human body may cause: − Muscular contractions − Respiratory failure − Fibrillation of the heart − Cardiac arrest − External and internal burns The severity and type of injury will depend on: − The size of current passing through the body − The time the current flows − The path taken by the current − Its frequency if it is ac Prevention of electrical accidents and incidents will include: • − The selection of suitable equipment for the environment (low voltage) − Correctly installed systems (completion certificate) − The use of protective devices: earthing, double insulation, fuse protection, circuit breakers, means of isolation − The correct use of equipment − Regular inspection and testing Manual handling injuries account for approximately 25% of all reportable injuries. The main causes of the injuries we have outlined are: − Failing to use a proper technique for lifting − Moving loads which are too heavy − Failing to grip the load in a safe manner − Not wearing approved protective equipment The Manual Handling Operations Regulations 1992 require employers to avoid the need to manually handle goods, and to assess the risk from manual handling operations which cannot be avoided. They identify four distinct elements to be considered when assessing risk from manual handling operations and when introducing safe working systems. These are the task, 5-58 Section 5 | Management of Common Hazards © RRC Business Training IOSH Managing Safely the load, the environment and the individual capability. The Regulations recognise the benefits to be gained from, and reinforces the requirement for, training staff in manual handling techniques. • The hazards of mechanical handling can be reduced by looking at the subject under four broad topics: Workplace Design − Materials storage facilities optional for height, reach and stability − Access which allows safe movement between fixtures, through doorways and across ramps − Transport; floor surfaces adequate for load, no obstructions in or over routeways, minimal traffic crossflows, minimal interference with pedestrians, adequate lighting, route markings and signs. Materials − Properly packed, secured or palleted in a way which ensures safe handling with the equipment in the works − Check for load stability, security of contents, special hazards, labelling. Equipment − The handling equipment must be of the right type to handle the loads in terms of power, strength and design − It must be properly maintained and tested on a regular basis by competent personnel and records kept − The equipment must be used within its specified design limits. Personnel − Are operators properly trained and supervised? − Do they wear appropriate personal protective equipment? − Is a safe system of work in place? • Hazardous chemical substances may exist in a variety of physical states, e.g. liquid, gas, fume, dust, and the state will affect the nature of the hazard. We have seen that specific risk phrases, such as toxic, harmful, corrosive, irritant, etc., are used to differentiate between degrees of chemical hazard. We also distinguished between the acute and chronic health effects of harmful substances. • We noted that the main routes of entry to the body by harmful substances were by inhalation, ingestion, absorption and injection. • The control measures for dealing with substances hazardous to health conform to a hierarchy which is of general application: − Elimination © RRC Business Training Section 5 | Management of Common Hazards 5-59 IOSH Managing Safely • − Substitution − Segregation/isolation − Suppression − Ventilation − Reduced time exposure − Personal protection − Training and education. The principal risks associated with display screen equipment are of physical (musculoskeletal) problems, visual fatigue and mental stress. They are effects which result largely from poor work organisation and job design and can be overcome in most instances by ensuring that the workstation conforms with established ergonomic principles. A small minority of people suffer work-related upper limb disorders and experience serious pain or disability arising from a badly designed workstation combined with excessive periods of continuous intensive keyboard work. The term WRULD (Work Related Upper Limb Disorder) also covers Repetitive Strain Injury (RSI), with tenosynovitis being the most common WRULD-related condition (an inflammation of the sheath surrounding the tendons, usually on the hand and wrist). Prevention is based on general ergonomic principles which include: • − Workplace design with ergonomically correct desks and chairs − Provision of rest breaks or change of duties to allow muscles and tendons to recover − Instruction to staff on adjustment of their workstations, need for steady pace with appropriate breaks, and reporting of any symptoms of WRULD. Exposure to excessive noise can induce hearing loss, depending on intensity, duration, frequency, and individual susceptibility. The effects may be temporary and gradually pass off after exposure ceases; there may be a ringing in the ears known as tinnitus. However, if exposure occurs over a long period, permanent damage may occur resulting in noise induced hearing loss. Noise control is based on the principles of recognition, measurement, evaluation and control. Use of personal protection (ear defenders) should be considered only as a last resort, except where it provides a short-term solution pending other action. − Machines and processes should be designed to produce less noise − Quiet machines or processes should be chosen when selecting production methods; get the supplier to specify noise levels at operator positions − Enclose noisy machines with sound-insulating panels − Put noisy machines and processes in separate rooms (isolation) − Fit silencers to exhaust systems − Operators in noisy areas should wear hearing protection − Make hearing protection available above 85 dB(A). 5-60 Section 5 | Management of Common Hazards © RRC Business Training IOSH Certificate | Managing Safely C O N T E N T S Section Title 6 Page Active Monitoring 6-1 General Principles of Active Monitoring 6-2 The Active Monitoring Inspection Process 6-5 Auditing Performance 6-15 The Audit Process 6-17 Carrying out an Audit 6-20 Summary 6-23 IOSH Managing Safely IOSH Managing Safely IOSH Certificate | Managing Safely Section 6 | Active Monitoring Learning Objectives When you have completed this section you should be able to: ! Differentiate between safety audits and safety inspections ! Explain the purposes and techniques of a health and safety audit ! Prepare and use active monitoring checklists ! Implement schedules for active monitoring, recording results and analysing records. Unit 6: © RRC Business Training Section 6 | Active Monitoring 6-1 IOSH Managing Safely GENERAL PRINCIPLES OF ACTIVE MONITORING Pro-active or active monitoring means checking things BEFORE they go wrong. It involves regular inspections and audits to ensure that controls are being implemented and standards of safety are being met. Because of the close relationship between inspections and audits, it is likely that on occasions the inspection may encroach on elements of the audit but it is important to differentiate between the two to avoid any confusion in terminology and practice. This section looks at the different monitoring systems and processes. Types of Monitoring Systems Safety Audit The safety audit can be considered as the review of management systems or processes which are or should be in place to minimise and control risk. Although the audit is a form of active monitoring, it will be discussed later in the section because of its importance in the overall management of health and safety. Active Monitoring Inspections The safety inspection can be considered as the review of the physical features ,workplace precautions and risk control systems which are, or should be, in place to minimise and control risk associated with an activity or situation. The main objective of the inspection is to promote higher standards in health and safety and not to find faults, although they can not be ignored. As such it is important that staff are involved and take ownership of identified problems. Active Monitoring Methods As part of the 'planning' element organisations must decide how to allocate responsibilities for monitoring at different levels in the management chain and what level of detail is appropriate. The various forms and levels of active monitoring include: • Systematic routine inspection of premises, plant and equipment by supervisors, management, safety representatives or other employees • Review of inspection reports by line managers/directors to confirm the frequency and quality of the inspections • Health and safety audit • Programmed maintenance and inspection of plant and equipment by maintenance staff, competent personnel and/or insurance engineers • Routine procedures to monitor specific objectives, e.g. quarterly or monthly reports or returns • Staff review and appraisal interviews where specific objectives relative to health and safety have been set • Periodic examination of documents to check that maintenance systems are being adhered to 6-2 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely • Environmental monitoring and health surveillance to check on the effectiveness of health control measures and to detect early signs of harm to health • Recording of accident-free periods. All monitoring forms should have benchmarks to allow comparisons of performance of specific sectors. To be effective each of the above monitoring systems must be systematic in its execution and documented to demonstrate compliance with the requirement to monitor health and safety under the Management of Health and Safety at Work Regulations. The Loss Management Model below shows how active monitoring can contribute to the overall management and improvement of safety within the workplace. Incident Reactive Monitoring Risk Assessment Investigations, Epidemiological analysis and corrective action (Pro)Active Monitoring Inspections, spot checks etc, and corrective action Workplace precautions & Risk Control Systems (RCS) Trend Analysis Trend Analysis Review Loss Management Model © RRC Business Training Section 6 | Active Monitoring 6-3 IOSH Managing Safely Activity 1 1. What THREE characteristics should active monitoring techniques have in common? 2. Identify what is described in the following definitions, (A) safety audit or (B) safety inspection (a) (b) Reviews the physical features and workplace precautions that are, or should be, in place. Reviews the management systems or processes that are or should be in place. Answers: (1) They must be systematic, documented to show compliance and have benchmarks for inter-industry comparisons. (2) (a) (B); (b) (A). 6-4 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely THE ACTIVE MONITORING INSPECTION PROCESS There are four different methods which can be used for active monitoring: • Location inspection • Activity observation • Document inspection • Record inspection. Each of these inspection techniques is used to actively monitor an organisation’s health and safety performance. The most commonly used is Location Inspection, which involves a visual inspection being carried out on the physical conditions actually present in the workplace of choice. Location Inspection To be fully effective the following aspects of an inspection must be considered: • Scope, frequency and level • Setting up an inspection team • Preparing a checklist • Inspection • Report and remedial action • Authorisation • Monitoring of inspections. Scope, Frequency and Level of Inspection Safety inspections may be restricted to specific elements in the interests of increasing frequency to more critical aspects of safety, e.g. weekly or monthly inspections of fire equipment (emergency exits, extinguishers, etc.). These may be carried out by a fire warden or facilities staff. More extensive inspections, relating to all aspects of the work area, are more likely to be carried out at monthly or three-monthly intervals by local managers or supervisors. The scope and frequency of inspections should be determined by: • The inherent risk associated with the work or area • The ability of staff to identify and rectify faults as and when they occur • The findings of previous inspections. Over-frequent inspections can lead to complacency with local managers completing inspection forms as a desk exercise. Infrequent inspections may result in faulty equipment guards, lifting carpet, etc., being accepted as the norm, resulting in accidents occurring. For low to medium risk areas, consider the benefits to be gained from the following arrangements: © RRC Business Training Section 6 | Active Monitoring 6-5 IOSH Managing Safely Frequency Staff involved 2 - 4 times a year Local staff Every 3rd or 4th inspection Local staff with the support of an internal 'competent' person Every 2 - 3 years Local staff with the support of an external 'competent' person Discussions which arise with staff external to the work area during the inspection promote staff development and help to provide a different perspective on arrangements. When determining the area to be included, it is recommended that it be restricted to that which can be covered within 1.5 - 2 hours (3 hours maximum), unless you have a comprehensive means of recording the details which will be necessary in preparing the report. Setting Up an Inspection Team Departmental or section inspections should be conducted by local managers with the involvement of local staff. As union appointed safety representatives have the legal right to conduct safety inspections at regular intervals, these members of staff should be invited to join the departmental inspection. In most instances the representatives will already have received training in the inspection process and can make a valuable contribution to the exercise. It is important that at least one member of the team is aware of the minimum legal standards identified within the Workplace (Health, Safety and Welfare) Regulations 1992 and the Provision and Use of Work Equipment Regulations 1998. The degree of training required for other staff will depend upon their degree of involvement and their role. Beware of the difficulties associated with a large inspection team. Where more than three people are involved, the efficiency and effectiveness is likely to decline. Preparing a Checklist The effectiveness and efficiency of an inspection depends upon the preparation of a checklist which can be used as an aide-memoire for spotting hazards and deficiencies. In many cases an organisation will provide a basic checklist which should be tailored to the specific needs of the various departments. Such a checklist should not be seen as the definitive list; it should be reviewed and developed in the light of experience and changes in legislation and standards. Below is a sample form which can be used as the basis for the inspection process. Different aspects of the checklist may be allocated to individual members of the team, helping to ensure the participation of all involved: • Part of the preparation is to forewarn staff of the inspection, confirming the suitability of the timing. In situations where standards are likely to have slipped, then advance notification will generally encourage those on site to review critically their own standards and take remedial action in advance of the inspection. Impromptu inspections by more senior managers can also contribute to the maintenance of standards but should not be considered as the norm. 6-6 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely • Varying the time and day of the week on which the inspection is carried out can help to take into account different work activity patterns. Previous inspection reports relating to the area or activity should be reviewed prior to the inspection to determine recurring problems. © RRC Business Training Section 6 | Active Monitoring 6-7 IOSH Managing Safely Sample Checklist General Arrangements 1. General 1.1 Exits: Y/N NA Notes Are exits and escape routes free from obstructions? Is there a fire evacuation notice clearly posted with assembly points indicated? (where appropriate) 1.2 Fire Equip.: Are fire extinguishers provided, appropriate and prominent? 1.3 First-Aid: Are First-Aid facilities adequately displayed and maintained? 1.4 Floor: Is the floor/ground safe, e.g. not slippery and free from tripping hazards, cables, rubbish? 1.5 Lighting: Is the lighting adequate for the work being performed? 1.6 Electrical: Are switches and sockets free from damage? Are the circuits adequately protected? Have all portable electrical units been tested in recent months? 1.7 Heating: Is the heating adequate for the work being carried out? 1.8 Ventilation: Is there adequate/appropriate ventilation or fume extraction for the work activity? 2. Fixed Equipment and Apparatus 2.1 Does the area have any apparatus or fixed equipment? Equipment: (This includes pumps, screens, welders, photo-copiers etc.) 2.2 If 2.1 is 'YES', has a maintenance schedule or checklist been completed in respect of each item, e.g. noise, fumes? 2.3 Is each item of equipment stable and adequately guarded? 3. Special Hazards 3.1 Are substances subject to COSHH Regulations used or stored in this area? 3.2 Is equipment subject to specific legislation used in this workplace, e.g. pressure vessels, lifting equipment? 3.3 If 3.1 and/or 3.2 is 'YES', have the requirements of the legislation been complied with? 6-8 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely 3.4 Are visitors adequately segregated from the work activities? 4. Personal Protective Equipment 4.1 Do activities/operations within the area require the use of personal protective equipment, e.g. goggles, ear defenders? 4.2 If 4.1 is 'YES', is there adequate and appropriate provision of personal protective equipment? 4.3 Are there appropriate storage and maintenance arrangements in place for the personal protective equipment? Notes: Report and Remedial Action When conducting the inspection, the team should attempt to discover the root cause of any unsatisfactory conditions found. Where possible, the report should make positive recommendations for addressing the underlying problems as well as their symptoms. • Reporting Findings Where practicable, it is important to discuss findings, minimum expected standards and options for remedial action on-site with those involved with the activity or situation. They may not have been aware that current arrangements do not conform to minimum expected standards. Be supportive and compliment positive findings. The experience of local staff will be more important to improving standards than the final report. • Recommending Remedial Action The report on the inspection is important at it provides the basis for departmental management to decide on remedial action and allows for monitoring by the organisation as a whole. It should include: − The date, names of team members, and identification of those areas/activities inspected − Positive findings, as well as details and significance of any failings discovered − Identification of standards to be achieved together with recommendations of how they may be reached − Timescale and priorities for remedial work − Identification of those responsible for ensuring recommendations are actioned − Provision for confirmation that remedial action has been completed (optional) − Relevant legislation (optional). Reference to relevant legislation on the report will: − Encourage local inspectors to focus on legislative standards and not use the inspection process as a means of updating facilities without just cause © RRC Business Training Section 6 | Active Monitoring 6-9 IOSH Managing Safely − Provide guidance for managers who are responsible for authorising expenditure to support remedial work − Provide a reference for managers who are responsible for carrying out remedial action. Authorisation Where the inspection team does not have the authority to commit necessary expenditure, a clear route must be established to ensure that appropriate action is authorised and instigated within a relatively short period following the inspection (ideally, no greater than five working days from the date of inspection). Monitoring Inspections Reporting on Progress Where provision for confirmation that remedial action has been completed does not appear on the reporting form, alternative formal arrangements must be in place for those charged with putting recommendations in place, so they can report on the work when completed. Alternatively, they will have to report on progress if the remedial work is likely to be extensive. Carrying out Spot Checks Following receipt of an inspection report, spot checks may be carried out in order to monitor the frequency and quality of inspections. Common faults, deficiencies or trends should be determined as such areas may benefit from training or a more radical approach. Activity 2 Who should be included in the team carrying out departmental inspections? Against correct alternative, write in what their role would be. (a) (b) (c) (d) Member of the Board Department managers Departmental managers Safety representatives (e) HSE representatives You should have ticked (b), (c) and (d). The inspection team should be led by departmental managers and safety representatives ((b) and (d)) to ensure that members have knowledge of legal standards and requirements, work procedures and organisational policies. Where possible, someone on the team should have the authority to recommend remedial action, even implement it. 6-10 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely To ensure ownership of the problems and solutions, departmental staff (c) should also be involved, although it is important to keep the number of team members small to ensure maximum efficiency. Other Active Monitoring Techniques As previously discussed, location inspection is just one of four active monitoring techniques that may be used in the workplace. The other three are: activity inspection, document inspection and record inspection. • Activity inspection involves actually watching people carry out tasks in the workplace and making note of the good or bad practices they use as they work. This form of active monitoring can be a very powerful tool because it complements the fact that many (if not most) workplace accidents are the results of unsafe acts rather than unsafe conditions. One of the weaknesses of any location inspection regime is that whilst it may be very effective at spotting and correcting unsafe conditions in the workplace, it often completely ignores the way in which people are actually behaving. Activity observation is specifically tailored to target behaviour. For example, one of the hazards of concern in an office workplace might be the manual handling of 23 Kg water bottles onto an office drink dispenser. The workplace precaution implemented might be that the job is made a two-man operation and correct two-man lifting technique, must be used. The risk control system for this is training for all members of staff who are expected to do the lifting, briefings to all staff so they know the rules and a notice on the wall above the store reminding staff of the two-man rule. Location inspection will, of course, spot if the sign is present or absent, but chances are a location inspection will not be carried out when the water bottles are being replaced. As a consequence, management will not know whether the rules are being adhered to or not. Activity inspection in this case would involve a supervisor or manager watching the bottle being replaced (probably without the workers’ knowledge) on a routine basis perhaps once every three or four months. Good practice would be complemented and bad practice challenged. A record of the observation and feedback provided to the workers concerned would be made. If underlying reasons for poor practice were identified, then they would be addressed. It is important to distinguish this formalised system of activity observations from the day-to-day supervision of staff, under which it would be expected that a supervisor would challenge unsafe behaviour when seen. Activity inspection involves formalising and scheduling this process to focus on key workplace precautions and risk control systems. • Record inspection involves checking that individual records have been made or created following health and safety actions. For these purposes a record is something created to log that an action has been taken. A new record is essentially created every single time the action is carried out and is not subsequently used except as a verifier that the action has indeed been carried out. For example, when a fire extinguisher is inspected and tested once a year by a competent engineer, a record should be made of the inspection and test. Record inspection would involve checking that log on an © RRC Business Training Section 6 | Active Monitoring 6-11 IOSH Managing Safely annual basis, at some time just after the check should have been made, to verify that the inspection has been carried out and that the log has been kept up-to-date. Any health and safety action which creates a record can be actively monitored in this way. For example, training or re-training usually involves the creation of a training record. Therefore, training records can be actively monitored to ensure they are current. Statutory inspections on pressure systems or lifting equipment require that a record is created. Therefore, such records can be actively monitored to ensure that the inspections have been carried out and the logs are up-todate. • Document inspection involves inspecting documents which are created or held by the organisation. A document (for these purposes) is something that is created and then may be used and read many times over its lifetime before being replaced/discarded. For example, the company health and safety policy is a document. Other examples might include acts and regulations, approved codes of practice and legal guidance notes, risk assessments, safe systems of work or safe operating procedures and the premises fire certificate. Many of these documents might not be inspected on a very frequent basis. They should, however, be read and checked on some kind of infrequent routine. For example, many organisations will inspect their company health and safety policy “statement of intent” on an annual basis to ensure that it remains up-to-date. Safe systems of work might be inspected on a yearly basis to ensure that they are still correct and up-to-date. Risk assessments might be inspected once a year or once every couple of years to ensure that they have been reviewed and up-dated to keep abreast of changes in the workplace and legislation. Key Management Activities of Relevance to Active Monitoring With all of these various forms of active monitoring, be it location inspection, activity observation, record inspection or document inspection, there are some central questions which management must address to allow active monitoring to be arranged: • What has to be checked? • What form will the check take? • What standard has to be met? • How frequent should the check be made? • Who will make the check? • How will they record their results? • What will happen to the results? The answers to these questions will depend on the hazard and risk level and the nature of the workplace. For example, if we consider a fork lift truck being used in a warehouse setting: 6-12 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely • Hazard - fork lift truck • Workplace precaution • − Operator following standard operating procedures − Truck in good working order Risk control system − The operator should inspect the truck before use every day − The truck should be inspected once every 6 months as an item of lifting equipment by a competent engineer − The truck should be maintained on a routine maintenance programme as dictated by the manufacturer − The operator should be trained to the appropriate standard. Now if we consider the various ways of actively monitoring the above situation we can see that all four methods of active monitoring can be applied: Location inspection: The warehouse supervisor might carry out a less frequent double-check of the fork lift truck to ensure that it is indeed in good condition. It could be done and logged once a fortnight or monthly. Activity observation: The warehouse supervisor might watch the fork lift truck in operation to ensure good technique is being practised. It could be done and logged once a fortnight or monthly. Alternatively, the supervisor might watch the operator carry out the daily start-up check to ensure that the check is being made and made correctly. Again, it could be done and logged once a fortnight or monthly. Record inspection: The warehouse manager might pull the daily start-up check sheet and check it to ensure that it has been filled-in correctly and any faults found duly rectified. This could be done every two or three months to keep operators on their toes. Alternatively, the manager might check the six-monthly lifting equipment inspection report to ensure that the inspection has been carried out and that any faults found were rectified. Obviously this would best be done every six months, shortly after the inspection was due. Document inspection: The site safety officer might check the company policy document which contains information on the inspection and maintenance regime for fork lift tucks to ensure that the document does in fact reflect current practice and current legislation. This could be done every year or every two years. © RRC Business Training Section 6 | Active Monitoring 6-13 IOSH Managing Safely Activity 3 Look at the following examples of active monitoring and decide which are examples of: (a) location inspection, (b) activity inspection, (c) record inspection, or (d) document inspection 1. A supervisor checks his staff training log once every six months to ensure all training is up-to-date. 2. A manager reads a safe system of work prodecural document once a year to ensure it is correct. 3. A line manager walks through his department once every three months with a checklist looking at housekeeping and fire precautions 4. A supervisor watches a member of staff strip down and clean a piece of catering equipment to ensure that the safe system of work is followed. Answers: 1(c), 2 (d), 3(a), 4(b). 6-14 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely AUDITING PERFORMANCE Auditing and reviewing performance is the final stage in the health and safety management control cycle (HS(G)65). It is an essential element of health and safety management because it provides feedback into all other elements of the cycle described in HS(G)65 in our first section. Performance Reviews Reviewing involves making judgments about the adequacy of performance and making decisions on the nature and actions necessary to remedy deficiencies. Organisations require feedback to determine if health and safety management systems are working effectively and to plan. The review of management systems provides valuable information on the effectiveness of arrangements in place for the management of health and safety. Identifying, through experience, both the strengths and weaknesses within a system helps in the re-modelling of planning and implementing arrangements for subsequent cycles associated with an activity. Reviews tend to consider the arrangements and effectiveness of discrete areas of safety management. Health and safety reviews within an organisation are likely to be conducted at three distinct levels: • Activity or substance review (e.g. as required under MHSWR or the Control of Substances Hazardous to Health Regulations) • Review of the execution and effectiveness of an individual management or monitoring activity (e.g. the safety inspection process - in this case the review considers the planning and implementation) • Review of the organisation's health and safety arrangements benchmarked against comparable organisations and national standards, i.e. legislation. Organisations should: • Decide on the frequency of the reviews at each level • Establish who is responsible for implementation • Set deadlines for completion. Information about how effective individual management systems are can be gathered from: • Audit reports • Inspection reports • Accident, ill-health and incident data. Health and Safety Audits The health and safety audit is an independent, critical, systematic examination of the systems which are or should be in place to manage effectively health and safety arrangements within an organisation. This form of audit follows the same criteria as that set for a financial audit - through a sampling process which generally addresses the full range of safety issues associated with an © RRC Business Training Section 6 | Active Monitoring 6-15 IOSH Managing Safely organisation and helps to determine and prioritise future resources into the safety management systems. Depending upon the size of an organisation, the best approach is to: • Identify the level of audit • Identify who will undertake the audit • Identify an appropriate system of audit. The audit may be conducted at one of three levels: Strategic Policy and Organisation Considers those policies and procedures determined by Senior Management and applies company-wide across all sectors under the control of the organisation, such as the effectiveness of the Safety Policy, Insurance cover, safety training and support. Tactical Planning Addresses the safety systems and approaches developed by divisions or departments. Where there are possible variations in policy and procedures within departments of the same organisation, audit would be carried out at operational level. Operational Implementation Each department or section is audited as a separate entity. In relatively small organisations, the audit is likely to be limited to one general audit. The frequency of an audit will to some extent be determined by its scale (time involved) and the number of weaknesses identified. The frequency may vary from once a year to once every three years. 6-16 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely THE AUDIT PROCESS Appointing Auditors Role of the Auditor The auditor or 'independent arbitrator/observer' should: • Interpret the law • Reconcile conflicting views • Provide evidence that duty has been properly performed • Report on non-fulfilment of obligations • Identify overall improvement or deterioration of standards. Using Internal or External Staff Using external consultants or staff from different sections or departments within an organisation to audit the arrangement within other sections ensures the audit remains independent. An external consultant can undertake an initial audit within a relative short period of time while the internal auditor reduces cost and takes ownership of the identified omissions. The independence offered ensures that there is an unbiased view and there should be no need to confirm the findings (assuming a reputable company is employed). As the audit will review compliance with internal procedures as well as with legislative requirements, it is possible that auditors may not be fully aware of some in-house systems and some omissions may occur. Measuring performance relies on the repetition of similar audits over a period of time and can only be achieved by following an identical format. Although questions within an audit are based on objectivity, it is not uncommon for some answers to be influenced by a certain level of subjectivity. This highlights the need for the audit to be carried out by the same person or by those who receive the same briefing if meaningful results are to be achieved. Thus the company must accept a financial commitment for regular audits at the outset. The use of internal staff to undertake the audit, with assistance from external personnel, should ensure ownership of faults identified and continuity of standards. Provided the staff involved are adequately trained and appreciate the benefits of an accurate and honest audit, then the likelihood of misinformation to achieve good performance figures should be avoided. Confirmation by means of random sampling, by a competent safety practitioner, would help to ensure standardisation and reliability of results. Selecting an Audit System The safety audit has been defined as: © RRC Business Training Section 6 | Active Monitoring 6-17 IOSH Managing Safely A systematic and independent examination of those arrangements made for achieving satisfactory health and safety standards in the workplace, to ensure they are adequate and effective and to provide information on whether any changes are necessary. Types of Audit System A system utilising numeric weighting to a series of questions is beneficial as it provides objective results which can be compared directly to future audits, so determining any changes in performance. This type of system is suited to target-setting management. A well-designed safety audit should check management's safety strategy, structure, systems and operations and should provide necessary feedback to senior management. A numeric-based system allows establishments to be compared relative to each other and allows benchmarks to be set. Safety audits can be divided into two distinct groups: Commercial audits In-house systems Provide a tried and tested system where time is at a premium. The advantage is that lessons can be learned from previous applications. May at first sight appear better value for money, but a manager should not underestimate the time necessary to develop a comprehensive and effective audit system. A number of commercial packages are available which can be tailored and expanded to meet the needs of individual establishments. Such packages may be computer and/or paper-based systems. Most commercial packages concentrate on developing the system, leaving the development of the audit questions to the purchasing organisation: • Paper systems can be utilised simultaneously within a number of departments or sections in an organisation, while the computer system may be limited by a multi-copy licence and require the availability of appropriate hardware. • Computer-based systems are generally more expensive than hardcopy systems as the base program usually has to be added to the cost, although potential savings exist in time for analysis, comparisons and report writing. Audit System Specification • Covers most, if not all, of the safety management issues • Is capable of being modified for specialist work • Provides numerical ratings in order that comparisons or improvements can be undertaken • Is objective to provide repeatable results • Is relatively easy to use by staff with limited training or experience in safety management 6-18 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely • Can be completed relatively quickly • Provides rapid feedback on points of concern • Encourages ownership of safety within establishments. Activity 4 Look at the following statements and indicate if they are TRUE (T) or FALSE (F). Health and safety audits: (1) Follow a rigid structure (2) Provide numerical ratings in order that comparisons or improvements can be undertaken (3) Are objective and provide repeatable results (4) Can only be carried out by specially trained staff with experience in safety management (5) Provide rapid and objective feedback on points of concern (6) Can be modified to meet the needs of specialist work. Answers: True (2), (3), (5), (6); False (1), (4), (6). © RRC Business Training Section 6 | Active Monitoring 6-19 IOSH Managing Safely CARRYING OUT AN AUDIT Gathering Information The audit process involves the collection of information and making judgments on the honesty of that information. Auditors are likely to have to draw from three different sources of information: Interviewing Individuals With the purpose of obtaining information about the health and safety management system and the perceptions of individuals as to its effectiveness. Interviewing helps establish the competence levels of individuals for dealing with health and safety issues. Such as: Examining Documents Visual Observation 6-20 Section 6 | Active Monitoring • Health and Safety Policy • Procedures for carrying out tasks • Minutes of safety meetings • Accident investigations Physical conditions and work activities can be observed visually to determine if stated procedures are being implemented. © RRC Business Training IOSH Managing Safely Auditing the Management Cycle Audits are designed to assess the following key elements of health and safety management: Policy Its intent, scope, adequacy and whether or not it sets realistic safety targets. Organisation • The acceptance of health and safety responsibilities by line management • The adequacy of arrangements to consult and empower employees • The effectiveness of communication on health and safety issues • The arrangements for ensuring the competence of staff. • The overall control and direction of the health and safety effort • The adequacy of risk control measures and risk assessment procedures. Planning Measuring Review Their adequacy, relevance and design. The ability of the organisation to: • Learn from experience • Improve performance • Develop the health and safety management system and • Respond to change. One of the most difficult aspects of the audit process is making judgments regarding the findings. If there are no clear standards, the assessment process will be unreliable. Legal standards, HSE guidance and applicable industry standards are used to form audit judgments. A comprehensive picture of the effectiveness of the health and safety management system will emerge from an audit and, from there, corrective actions can be put in place where necessary. Writing the Audit Report Care must be taken in the presentation of the report to ensure that recommendations are prioritised. Where a scoring system has been used it must be emphasised to managers that the system is there to help them to focus on the key areas to be addressed. A comprehensive picture of the effectiveness of the health and safety management system will emerge from an audit and from there, corrective actions can be put in place where necessary. © RRC Business Training Section 6 | Active Monitoring 6-21 IOSH Managing Safely Following the process advocated within HS(G)65, arrangements must be made for the planning and implementation of the recommendations. Activity 5 Which of the following sources of information would safety auditors use? (Tick the appropriate ones then check your answers with the above text) (1) (2) (3) (4) (5) (6) (7) (8) Accident reports HSE guidance Company newsletters Interview Observation Photographs Safety reports Industry standards. 6-22 Section 6 | Active Monitoring © RRC Business Training IOSH Managing Safely SUMMARY Pro-active monitoring involves the review of facilities and systems before accidents take place. Safety inspections can be considered as the review of physical features, workplace precautions and risk control systems; while safety audits can be considered as the review of safety management systems. Active monitoring inspections can be broken down into four principle types: • Location inspections • Activity inspections • Record inspections • Document inspections. Safety inspections benefit from a formalised approach which identifies the scope and frequency, inspection team, preparation, inspection, report, authorisation of remedial work, confirmation of action completed and monitoring for trends. A safety inspection report should record: • Date of inspection • Names of inspectors • Area inspected • Findings • Identification of minimum standards/Recommendations • Timescale and priority for remedial work • It may also identify those responsible for remedial work. Audits are designed to assess the key elements of the health and safety management system (as outlined in HSG65): Policy Its intent, scope, adequacy and whether or not it sets realistic safety targets Organisation The acceptance of health and safety responsibilities by line management, the adequacy of arrangements to consult and empower employees, the effectiveness of communication on health and safety issues and the arrangements for ensuring the competence of staff Planning The overall control and direction of the health and safety effort and the adequacy of risk control measures and risk assessment procedures Measuring Review © RRC Business Training Their adequacy, relevance and design The ability of the organisation to learn from experience, improve performance, develop the health and safety management system and respond to change. Section 6 | Active Monitoring 6-23 IOSH Managing Safely Audits are: • Systematic: a structured approach must be followed • Independent: best carried out by people who are not in the management system being audited • Comprehensive: all aspects of the health and safety management system must be examined • Critical: areas of weakness must be highlighted to allow for continuous improvement. 6-24 Section 6 | Active Monitoring © RRC Business Training